Question

In which case a prison inmate sent a letter to the Supreme Court, describing physical torture, which became a pioneer in public interest litigation, though the court later abandoned the practice of considering letters?

• A. Mukti Morcha vs. Union of India
• B. The Narasimha Rao case
• C. Hussainara Khatoon vs. Bihar case
• D. Sunil Batra vs. Delhi Administration

Hint:

The Sunil Batra case marked the beginning of “epistolary jurisdiction” in India — where even letters could be treated as writ petitions to protect fundamental rights.

Answer 1

The Correct Option is D

Step 1: Case background.
In the case of Sunil Batra vs. Delhi Administration (1978), a prison inmate wrote a letter to the Supreme Court complaining of brutal physical torture inflicted on another prisoner. The Court treated the letter as a writ petition under Article 32 of the Constitution, marking one of the earliest examples of Public Interest Litigation (PIL) in India.
Step 2: Legal significance.
This case highlighted the judiciary’s proactive role in safeguarding prisoners' rights and ensuring humane treatment in jails. It expanded access to justice by allowing informal communication (letters) to be treated as petitions.
Step 3: Later development.
Though the Court initially entertained such letters, it later restricted this practice to prevent misuse, emphasizing formal procedure.
Step 4: Analysis of options.
(A) Incorrect — Mukti Morcha dealt with bonded labour, not prisoner rights.
(B) Incorrect — The Narasimha Rao case relates to parliamentary privileges, not PIL.
(C) Incorrect — Hussainara Khatoon case dealt with speedy trials for undertrials, not letters from inmates.
(D) Correct — Sunil Batra’s letter initiated the case that became a landmark in PIL history.
Step 5: Conclusion.
The correct answer is (D) Sunil Batra vs. Delhi Administration, which pioneered the concept of epistolary jurisdiction.