Question

Which of the following is not a case of Public Interest Litigation:

• A. Kesavananda Bharti. v. State of Kerala AIR 1973 SC 1461
• B. Vincent Narayan v. Union of India, AIR 1988 SC 889
• C. Union of India v. Association for Democratic Reforms, AIR 2002 SC 2112
• D. Vincent Panikurlangara v. Union of India, AIR 1987 SC 990.

Hint:

While Kesavananda Bharati had immense public importance, it was a traditional constitutional law case. PIL, as a distinct category, emerged later to address issues of human rights, environment, and governance on behalf of the public.

Answer 1

The Correct Option is A

Kesavananda Bharati v. State of Kerala is a seminal case on constitutional law that established the 'basic structure doctrine,' limiting Parliament's power to amend the Constitution. While it was brought by an individual whose property rights were affected, its scope was a fundamental constitutional challenge, predating the modern concept of PIL which evolved in the late 1970s. The other cases are classic examples of PIL: Vineet Narain (Hawala scam, CBI independence), ADR (electoral reforms), and Vincent Panikurlangara (banning harmful drugs, public health).