Consider the following statements: 1. Justice V. R. Krishna Iyer was the Chief Justice of India. 2. Justice V. R. Krishna Iyer is considered as one of the progenitors of public interest litigation (PIL) in the Indian judicial system. Which of the statements given above is/are correct?

Justice V. R. Krishna Iyer is widely recognised as one of the pioneers of public interest litigation in India; several accounts explicitly pair him with Justice P.N. Bhagwati as early architects of the PIL/SAL approach to broaden access to justice [1]. However, Krishna Iyer was appointed as a judge of the Supreme Court of India (in 1973) and is not recorded as having served as Chief Justice of India; official Supreme Court/biographical records identify him as a Justice of the Supreme Court rather than a Chief Justice [2]. Therefore statement (1) is incorrect and statement (2) is correct.

Sources

1. [1] Indian Polity, M. Laxmikanth(7th ed.) > Chapter 29: Public Interest Litigation > Public Interest Litigation > p. 309
2. [2] https://www.sci.gov.in/judge/justice-v-r-krishna-iyer/