Has the doctrine of locus standi come full circle? Discuss with reference to recent attempts to restrict public-interest challenges to large infrastructure projects.

Locus standi means the right to bring a case to court. The Supreme Court widened it in S.P. Gupta v. Union of India (1981), letting any bona fide person sue on behalf of those who cannot reach the courts themselves [1]. Recent pushback against public-interest litigation (PIL) on infrastructure projects is a partial reversal, not a full circle.

From liberalisation to restraint

• Liberal phase: PIL let public-spirited citizens defend the rights of socially oppressed groups. This displaced the old rule that only the injured person may sue [1].
• Correction phase: State of Uttaranchal v. Balwant Singh Chaufal (2010) told courts to verify petitioners' credentials and curb PILs filed with oblique motives [2].

Signs of the circle closing: the Great Nicobar case

• The Centre has filed a Special Leave Petition (SLP) asking the Supreme Court to stay Calcutta High Court hearings on petitions alleging that the ₹92,000-crore project violated the Forest Rights Act (FRA), 2006 [3].
• It calls the petitions an "abuse of process" and says petitioner Meena Gupta has no locus standi. It also argues that growth cannot be stopped by "claims of private individuals" [3].
• The government presents the project as strategically important, which raises the cost of delay [4].

Why the circle is not complete

• Courts hold the line: on 6 May 2026 the Calcutta High Court rejected the Centre's standing objection and cleared the case for final hearing [3].
• Credible petitioner: Gupta is a former Secretary of the Environment Ministry (MoEFCC) and the Tribal Affairs Ministry, hardly a busybody [3].
• Affected groups have no voice in court: the Shompen, a Particularly Vulnerable Tribal Group (PVTG), cannot realistically go to court themselves. A strict standing rule would leave their consent claims unheard, the very gap S.P. Gupta was meant to fill [1].
• The merits are untested: the SLP challenges only a preliminary ruling. Whether valid gram sabha consent was obtained, rather than only a Tribal Affairs Ministry No Objection Certificate, is still undecided [3][5].

The legitimate concern

• Repeated litigation can stall strategic assets. The remedy is Chaufal-style screening of motives, not a blanket bar on who can sue [2].

The doctrine has therefore moved from liberalisation towards restraint, but it has not returned to its pre-1981 rigidity. Courts should filter out frivolous PILs through credential checks and fast-track genuine ones to final hearing. This protects both development and access to justice under Articles 32 and 226 for the most vulnerable, in the spirit of SDG 16.