In S.P. Gupta v. Union of India (1981), the Supreme Court expanded the scope of Public Interest Litigation (PIL) by relaxing the rule of ______, allowing public-spirited persons to file petitions for enforcement of rights of marginalized groups unable to approach courts themselves.

S.P. Gupta (1981) PIL and locus standi: (a) Context: Petition regarding judicial appointments; broader issue of access to justice for marginalized groups, (b) Supreme Court holding: (i) Relaxed locus standi (personal injury requirement) for PIL cases, (ii) Any citizen/public-spirited organization can file petition for enforcement of rights of persons unable to approach court due to poverty, ignorance, or social disadvantage, (iii) Transformed judicial role: From dispute resolution to social justice delivery, (c) Applications: (i) Prison conditions: Hussainara Khatoon (undertrial release), Sunil Batra (prison reforms), (ii) Environmental protection: MC Mehta cases (Ganga pollution, vehicular emissions), (iii) Gender justice: Vishaka (workplace sexual harassment), (iv) Bonded labour: Bandhua Mukti Morcha (release, rehabilitation), (d) Safeguards: (i) Courts developed filters to prevent frivolous PILs; focus on genuine public interest, marginalized groups, (ii) Balance: Access to justice for marginalized vs preventing judicial overreach, (e) Rationale: (i) Substantive equality: Formal rights meaningful only with access to enforcement mechanisms, (ii) Democratic participation: PIL enables citizen engagement in governance, accountability, (iii) Social justice: Courts address systemic inequalities affecting marginalized groups, (f) Illustrates participatory constitutionalism: Rights realization requires active citizen engagement alongside institutional mechanisms; PIL bridges gap between legal recognition and practical realization of justice.