Who among the following was the Chief Justice of India when Public Interest Litigation (PIL) was introduced in the Indian Judicial System?

Public Interest Litigation (PIL) was introduced in the Indian judicial system in the late 1970s and early 1980s, marking a significant shift from the traditional rule of locus standi [2]. This legal innovation is primarily attributed to the judicial activism of Justice V.R. Krishna Iyer and Justice P.N. Bhagwati [3]. While Justice Krishna Iyer laid the groundwork in cases like Sunil Batra vs. Delhi Administration (1980), Justice P.N. Bhagwati is widely regarded as the 'founding father' of PIL in India for formalizing the concept and introducing epistolary jurisdiction. P.N. Bhagwati served as the 17th Chief Justice of India from July 1985 to December 1986, during the period when PIL became firmly established as a tool for social justice [1]. His landmark judgment in S.P. Gupta vs. Union of India (1981) further solidified the legal framework for PIL.

Sources

1. [1] Laxmikanth, M. Indian Polity. 7th ed., McGraw Hill. > Chapter 29: Public Interest Litigation > Public Interest Litigation > p. 309
2. [2] Indian Constitution at Work, Political Science Class XI (NCERT 2025 ed.) > Chapter 6: JUDICIARY > JUDICIAL ACTIVISM > p. 135
3. [3] https://en.wikipedia.org/wiki/Public_interest_litigation_in_India