With rise in PIL jurisprudence, the SC has shifted from being a mere constitutional or appellate court to an institution of governance. The latest flashpoint is the PIL in Sabarimala Case. In Sabarimala, the PIL to declare Sabarimala custom of barring women in menstrual age group to enter the temple was filed by non- Ayyappa followers. Justice Indu Malhotra writing the dissent held that the PIL is not mantainable as the petitioners were not directly affected by the Sabarimala custom. However, Justice Nariman and Chandrachud said that in matters, which affect the fundamental rights of individuals, locus standi should be seen broadly, thus holding the right of Indian Young Lawyers Association as petitioner in the case. Through court judgments, we look at the issue of relaxation in locus standi in fundamental rights cases. The pivot in evolution of PIL jurisprudence has been Article 32 of the Constitution. Under this, any citizen can petition the Supreme Court for enforcement of fundamental rights guaranteed in the Constitution. In a way, Article 32 connects the highest court directly to the In three decades of PIL jurisprudence, it would be interesting to see how SC has looked at the issue of locus standi in fundamental rights cases. The post looks at the standing of the petitioners where the SC has examined the question of freedom of religion. Were the group of petitioners directly or did the court allow non-followers to pursue religious freedom cases in larger public interest The general principle is that Supreme Court will not hear a party under Article 32 petition unless he has sufficient stake. With increased hearing on PIL matters, the SC has liberalized the standing barrier by widening the definition of “aggrieved person”.

1954
The Commissioner, Hindu vs Sri Lakshmindra Thirtha Swamiar
1957
Sri Venkataramana Devaruand vs The State Of Mysore
1961
The Durgah Committee, Ajmer vs Syed Hussain Ali
1979
Hussainara Khatoon vs State of Bihar
1981
SP Guota vs UOI
1983
PUDR vs UOI
1983
Bandhua Mukti Morcha vs UOI