Question

Under the constitutional framework of India, the Supreme Court gradually relaxed the traditional rule of locus standi, thereby allowing public-spirited individuals to approach the Court for enforcement of fundamental rights of others. This development is most closely associated with:

• A. Enforcement of fundamental rights through individual petitions alone.
• B. Judicial review of administrative action.
• C. The evolution of Public Interest Litigation.
• D. Expansion of writ jurisdiction under Article 226.

Hint:

Locus Standi Relaxation = PIL! If you see "public-spirited individuals" approaching the Court for others, it is definitely a PIL.

Answer 1

The Correct Option is C

Tracing the story chronologically makes the answer clear. Through the late 1970s and into the 1980s, the Supreme Court began hearing cases brought not by the injured persons themselves but by lawyers, journalists and social workers writing on their behalf, often construed simply as letters to the Court.

Cases about undertrial prisoners left in jail for years, bonded labourers unable to travel to a courtroom, and pavement dwellers facing eviction, none of these litigants could realistically have filed a formal petition in their own name. The Court chose to hear these matters anyway, reasoning that the traditional insistence on a personally aggrieved petitioner would leave the poorest and most vulnerable people without any real access to justice.

That sustained practice, repeated across many cases through the decade, hardened into a recognised doctrine allowing any public-spirited person to invoke the Court's jurisdiction for the enforcement of someone else's fundamental rights. That doctrine is Public Interest Litigation.

Judicial review of administrative action and the expansion of writ jurisdiction under Article 226 are both older or separate ideas about the scope of the Courts' powers, neither one specifically describes this shift in who may bring a case.
\[ \boxed{\text{The evolution of Public Interest Litigation.}} \]

Answer 2

Another way to separate these four options is to ask what specific question each doctrine answers, and match that question to what the facts in the passage describe.

1. (A) Enforcement of fundamental rights through individual petitions alone: This answers the question "who may approach the Court", but with an answer that is the reverse of what actually happened, since only the affected person could move the Court under this approach. This option is incorrect.
2. (B) Judicial review of administrative action: This answers the question "can the Court examine whether the executive acted lawfully", a question about the legality of government decisions, unrelated to who is permitted to file the case. This option is incorrect.
3. (C) The evolution of Public Interest Litigation: This answers the exact question the passage raises, "who may approach the Court on behalf of someone else", by allowing public-spirited persons to do so where the affected persons cannot act for themselves. This option is correct.
4. (D) Expansion of writ jurisdiction under Article 226: This answers the question "how wide are the High Courts' remedial powers", a question about the range of relief available, not about who is entitled to seek that relief. This option is incorrect.

Matching the question each doctrine answers to the situation described shows that only Public Interest Litigation concerns the relaxation of standing for public-spirited petitioners.

Therefore, the correct answer is The evolution of Public Interest Litigation.