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

Hint:

If a question contains the phrases "public-spirited person," "social activist," "relaxation of locus standi," or "rights of disadvantaged groups", the answer is usually Public Interest Litigation (PIL).

Answer 1

The Correct Option is A

Certain landmark cases of the late 1970s and 1980s show exactly what the Supreme Court was doing when it loosened the rule of locus standi, and lining up each option against those cases helps identify the right answer.

1. The evolution of Public Interest Litigation: In cases like S.P. Gupta v. Union of India and People's Union for Democratic Rights v. Union of India, the Court expressly allowed public-spirited individuals and organisations to file petitions on behalf of workers, prisoners and other groups who could not approach the court themselves. These are the founding cases of Public Interest Litigation, and they are built entirely around this relaxed approach to standing.
2. Judicial review of administrative action: Cases on judicial review, testing whether an administrative order is arbitrary or unreasonable, focus on the merits of the decision under challenge. They do not turn on whether the petitioner was personally affected by that decision, so they belong to a different strand of constitutional law.
3. Enforcement of fundamental rights through individual petitions alone: If the law had stayed limited to individual petitions, none of the PIL cases mentioned above could have been entertained at all, since the petitioners in those cases were often not the persons whose rights were directly infringed. This option describes the very limitation that PIL case law overturned.
4. Expansion of writ jurisdiction under Article 226: Article 226 cases mostly deal with the geographical and substantive scope of High Court writ powers. They do not turn on relaxing who can file the writ petition, so they sit outside the specific development the question is pointing to.

The cases that actually relaxed locus standi are the founding cases of Public Interest Litigation, so that is the development being described.

So, the correct answer is the evolution of Public Interest Litigation.

Answer 2

Constitutional law questions like this one can often be resolved by first asking which specific legal dimension each option belongs to, standing, meaning who can sue, jurisdiction, meaning where a court can act, grounds of review, meaning why a decision can be struck down, or remedy, meaning what a court can order. Sorting the options along this dimension makes the answer clear.

1. The evolution of Public Interest Litigation: This sits squarely on the dimension of standing. PIL exists precisely because the Court accepted that a person need not be personally aggrieved to seek enforcement of another's fundamental rights, which directly answers the who can sue question the facts are describing.
2. Judicial review of administrative action: This sits on the dimension of grounds of review, asking why a decision can be quashed, arbitrariness, illegality, mala fide exercise of power, and so on. It presupposes someone with standing has already approached the court; it does not itself deal with who that someone can be.
3. Enforcement of fundamental rights through individual petitions alone: This is also about standing, but it describes the strict, traditional position rather than any relaxation, since it limits enforcement to the very person whose right was violated. It is the baseline the Court departed from, not the development the question asks about.
4. Expansion of writ jurisdiction under Article 226: This belongs to the dimension of jurisdiction, concerning which courts can issue writs and over what territorial or functional reach, rather than who is permitted to invoke that jurisdiction.

Once the options are sorted by which legal question they actually answer, only Public Interest Litigation directly answers the who may approach the court question that the relaxation of locus standi is about.

Hence, the correct answer is the evolution of Public Interest Litigation.