Writ Petitions & High Court — Article 226 — ASK Law Xperts Delhi
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Writ Petitions & High Court रिट याचिकाएं और उच्च न्यायालय — Article 226 — Constitution of India

A complete guide to filing Writ Petitions before the High Court under Article 226 of the Constitution — covering the five types of writs (Mandamus, Certiorari, Prohibition, Habeas Corpus, Quo Warranto), Public Interest Litigation (PIL), locus standi, the alternative remedy doctrine, and landmark SC judgments on constitutional law and fundamental rights enforcement.

Article 226 — HC Writ 5 Types of Writs Mandamus / Certiorari Habeas Corpus PIL — Public Interest Alternative Remedy

Bar Council of India Disclaimer: This page is for general informational purposes only and does not constitute legal advice. Writ petitions involve complex constitutional law — always consult a qualified advocate.

Five Writs — पाँच रिट
Article 226 High Court — Five Types of Writs at a Glance
Five Types of Writs — Article 226 High Court India FIVE WRITS — ARTICLE 226 HIGH COURT | ARTICLE 32 SUPREME COURT Mandamus "We Command" Directs authority to perform public duty e.g. Force police to register FIR Most common writ Certiorari "To be certified" Quashes order of inferior court / quasi-judicial body Corrective — after the illegal act Prohibition "To Forbid" Prevents inferior court exceeding jurisdiction Preventive — before the act occurs Habeas Corpus "You have the body" Releases person from illegal / unlawful detention Anyone can file — not just detainee Quo Warranto "By what authority" Challenges right to hold public office Illegal appointment to public position Public office only Art. 226 HC: Against any person / authority / government | Art. 32 SC: Only for Fundamental Rights enforcement Constitution of India | Article 226 | Article 32 | ASK Law Xperts — asklawxperts.com
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Writ Petitions — Article 226रिट याचिका — संविधान का अनुच्छेद 226

A Writ Petition is filed directly in the High Court when a government authority has done something illegal, failed to do its duty, or detained someone without legal authority. There are 5 types: Mandamus — order the authority to do its job; Certiorari — cancel an illegal order; Prohibition — stop an inferior court from exceeding its power; Habeas Corpus — release an illegally detained person; Quo Warranto — challenge an illegal appointment to a public post. PIL is a special type — anyone can file it for public interest matters affecting many people. The HC can also grant a stay (interim relief) while the main case is pending.
रिट याचिका — High Court में सीधे दाखिल की जाती है जब: सरकारी अधिकारी ने गैरकानूनी काम किया हो, अपना कर्तव्य न निभाया हो, या किसी को गैरकानूनी हिरासत में रखा हो। पाँच प्रकार: Mandamus (काम करवाना), Certiorari (आदेश रद्द करना), Prohibition (सीमा से बाहर जाने से रोकना), Habeas Corpus (गैरकानूनी हिरासत से मुक्ति), Quo Warranto (सार्वजनिक पद पर अवैध नियुक्ति चुनौती)। PIL — सार्वजनिक हित में कोई भी दाखिल कर सकता है। HC interim stay भी दे सकता है।

Types of Writs — When Each Applies

Mandamus — "We Command"
Most Common Writ — Against Public Authority
Directs authority to perform a public duty it has failed to perform
Prior demand and refusal must be shown
Examples: force police to register FIR, compel govt. to issue licence
Duty must be public, legal, and non-discretionary
Cannot issue against purely private persons
Certiorari — "To be Certified"
Quashes Completed Illegal Order
Quashes order of inferior court / quasi-judicial body
Grounds: without jurisdiction, excess of jurisdiction
Violation of principles of natural justice
Manifest error of law on the face of the record
Post-event remedy — corrects completed illegal act
Prohibition — "To Forbid"
Preventive — Stops Jurisdictional Excess
Prevents inferior court from exceeding jurisdiction
Issued before the act occurs — preventive in nature
Petitioner must show clear case of jurisdictional excess about to happen
Unlike certiorari — acts before the decision is made
Rarely granted — strong prima facie case required
Habeas Corpus — "You Have the Body"
Most Powerful Personal Liberty Writ
Secures release from illegal / unlawful detention
Anyone can file — not just the detained person
Authority must produce person and justify detention
If detention illegal — court orders immediate release
K.S. Puttaswamy (2017): privacy is FR — HC protects it
Quo Warranto — "By What Authority"
Challenges Illegal Public Office Holding
Challenges person's legal authority to hold a public office
Applies only to public offices — not private positions
Example: challenging illegal appointment to statutory body
Any person can file — not just directly affected parties
Court can direct person to vacate the public office
PIL — Public Interest Litigation
Writ for Public Benefit — Relaxed Locus Standi
Any bona fide person can file — no direct interest needed
For rights of disadvantaged / issues of public concern
Bandhua Mukti Morcha (1984): even a letter can be PIL
Frivolous PILs dismissed with heavy costs
SC/HC can issue continuing mandamus to monitor compliance

Article 226 (HC) vs Article 32 (SC)

AspectArticle 226 — High CourtArticle 32 — Supreme Court
ScopeFundamental Rights AND any other legal right — broaderOnly for Fundamental Rights enforcement — narrower
RespondentsAny person, authority, or government within HC's territorial jurisdictionAny person, authority, or government anywhere in India
NatureDiscretionary — HC may refuse on alternative remedy, delay, lachesThe right to move SC for FR enforcement is itself a FR (Art. 32)
Alternative remedyGenerally insisted upon — three exceptions: FR violation, natural justice breach, jurisdictional excess (Whirlpool 1998)Also applied but less strictly for genuine FR cases
PILHC entertains state/local level PILs under Art. 226SC hears national-level PILs — Vishaka, Bandhua Mukti Morcha, Electoral Bond cases
Forum selectionFile in HC having jurisdiction over cause of action or respondentAppropriate for national importance or where multiple HCs involved

Filing a Writ Petition — Step by Step

1
Identify Writ Type, Forum & Exhaust Alternative Remedy
Determine which writ applies — mandamus (duty), certiorari (quash order), habeas corpus (illegal detention), prohibition (stop action), quo warranto (public office). Confirm HC jurisdiction — where cause of action arose, where respondent authority is located, or where petitioner resides. Critical: exhaust the alternative statutory remedy first — unless fundamental rights are violated, natural justice is breached, or there is a clear jurisdictional excess (Whirlpool 1998 SC). In Delhi — HC has jurisdiction over Central Govt. authorities and Delhi State authorities.
2
Draft the Writ Petition
A writ petition contains: (a) Heading — In the High Court of Delhi at New Delhi; (b) Parties — petitioner(s) and respondent(s); (c) Synopsis and List of Dates; (d) Jurisdictional facts — Article 226, relevant statute; (e) Facts of the case — chronological, clear; (f) Grounds — specific legal grounds challenging the impugned action; (g) Prayers — precise reliefs sought including interim stay. Attach: the impugned order, prior correspondence with authority, relevant documents, and a sworn affidavit. Pay court fee as per Delhi HC Rules.
3
Filing & Admission Hearing
File at the HC Registry — Single Bench or Division Bench depending on the category. At the admission hearing: court considers prima facie case, balance of convenience, and irreparable injury. If admitted — court issues notice to respondents and may grant a stay/interim order simultaneously. Many petitions are disposed at the admission stage itself — especially where the law is clear. For urgent matters — mention before the court for listing on urgent basis. e-filing is available on Delhi HC portal for registered advocates.
4
Counter Affidavit by Respondents
After notice — respondents (government / authority) file a counter affidavit within the time directed. Counter affidavit contains the respondent's version and justification for the challenged action. Petitioner may file a Rejoinder affidavit in reply. In habeas corpus — the detaining authority must physically produce the person before the court and justify the detention with documentary authority. Petitioner's advocate examines the counter affidavit carefully to refine the arguments and identify weaknesses in the respondent's case.
5
Arguments
Both sides make oral arguments on: (a) Jurisdiction and maintainability; (b) Locus standi — does the petitioner have standing? (c) Alternative remedy — was it exhausted? (d) Merits — is the impugned action illegal, arbitrary, without jurisdiction, or violative of natural justice? Advocate cites: constitutional provisions (Articles 14, 19, 21, 226), relevant statute, and binding precedents from SC and HC. Respondents typically argue: alternative remedy available, no locus standi, no FR violation, and the action was legal and proportionate.
6
Order, Enforcement & Appeal
HC passes one of: (a) Allow — directing authority, quashing the order, releasing detenu, or directing fresh consideration with reasons; (b) Dispose with directions — liberty to approach appropriate forum; (c) Dismiss — no merit found. HC orders are binding on all authorities within its jurisdiction — non-compliance invites contempt of court under the Contempt of Courts Act, 1971. Appeal from HC writ order: SLP to SC / Letters Patent Appeal within HC / Review petition before same HC bench. Always file a certified copy of the HC order immediately after it is passed.

Documents Required

📋Copy of impugned order / action being challenged
📄Correspondence with government / authority (all prior letters)
📋Orders / replies from lower authorities — showing exhaustion of remedy
🪪Petitioner's ID proof — Aadhaar / passport
📋Affidavit sworn by petitioner verifying facts in petition
📋Statutory notification / government order being challenged
📋Detention order (for habeas corpus — police remand / detention order)
📋Relevant judgments and legal provisions to be relied upon

Key Points

⚖️ Key Points — Writ Petitions
Article 226 — ForumHigh Court — any legal right, not just FR
Article 32 — ForumSupreme Court — only Fundamental Rights
Limitation periodNo fixed limit — laches and delay considered
Alternative remedy ruleExhaust first — 3 exceptions: FR, natural justice, jurisdiction
PIL locus standiAny bona fide person — no direct interest needed
Habeas corpus — who can fileAny person — not just the detained person
Non-compliance with HC orderContempt of Court — Contempt of Courts Act 1971
Appeal from HC writ orderSLP to SC / LPA within HC / Review petition
Frivolous PIL consequenceDismissed with heavy costs — SC directions 2022-24

Relevant Constitutional Provisions & Statutes

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Constitution of India — Articles 226 & 32
Article 226: HC's power to issue writs — against any person, authority, or government — for enforcement of fundamental rights and for any other purpose. Broader scope than Art. 32. Article 32: SC's power to issue writs — only for enforcement of fundamental rights — is itself a fundamental right (Part III, cannot be suspended except during Emergency under Art. 359). Article 13: Laws inconsistent with fundamental rights are void. Articles 14 (equality), 19 (freedoms), 21 (life and liberty) are most commonly invoked in writ petitions.
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Contempt of Courts Act, 1971
Governs civil contempt (disobedience of HC order) and criminal contempt (scandalising the court). Non-compliance with HC writ order — civil contempt under S.2(b). Punishment: simple imprisonment up to 6 months, fine up to ₹2,000, or both. HC has inherent power under Article 215 Constitution to punish for contempt. Contempt is the primary enforcement mechanism when government authorities defy HC orders — very effective tool.
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Delhi High Court Act & Rules — Original Side
Delhi HC has its own Original Side Rules governing writ petitions — WP(C) for civil writs, WP(Crl) for criminal/habeas corpus, WP(PIL) for public interest litigation. Filing fees, affidavit format, synopsis requirements, number of copies all prescribed. Judges Roster: specific benches for service matters, environment, consumer, matrimonial, criminal writs. e-filing available on Delhi HC portal for registered advocates — mandatory for certain categories.
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Administrative Tribunals Act, 1985
Service matters of Central Government employees — Central Administrative Tribunal (CAT) has exclusive original jurisdiction under Article 323A. Writ petition to HC is not directly maintainable in Central Govt. service matters — remedy is first before CAT, then HC under Article 226. SC in L. Chandra Kumar (1997): HC's supervisory jurisdiction over CAT orders under Article 226 cannot be excluded — HC is the superior court. Important for government employees' writ matters in Delhi.
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Right to Information Act, 2005
RTI Act provides an alternative remedy for obtaining information from public authorities — through PIO → First Appellate Authority → Central/State Information Commission. Writ petition challenging denial of information or CIC order — file in HC only after exhausting RTI machinery. RTI is a powerful pre-writ tool — use it to obtain government records, files, and orders that form the factual basis of the writ petition. Denial of RTI can itself be challenged by writ if CIC has dismissed.
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Legal Services Authorities Act, 1987
NALSA and DLSA provide free legal representation in HC and SC for eligible persons. State Legal Services Authorities run legal aid clinics — can assist in filing writ petitions for persons who cannot afford advocates. Fundamental right to legal aid — Article 39A Constitution — also applicable in criminal writ matters (habeas corpus). A PIL can also be initiated through Legal Services Authorities for systemic public interest matters.

Landmark Judgments

Landmark — PIL & Locus Standi Bandhua Mukti Morcha v. Union of India & Ors. Supreme Court of India | AIR 1984 SC 802 | Justice P.N. Bhagwati
Landmark PIL judgment expanding Art. 32 / 226 — held that any person acting bona fide for disadvantaged persons can file a writ on their behalf. Introduced epistolary jurisdiction — a letter or postcard to the SC can be treated as a writ petition if it discloses a FR violation. The rule of locus standi is relaxed in public interest matters. Justice Bhagwati held that courts must be accessible to the poor — not just the rich who can afford advocates.
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Landmark — Alternative Remedy Exceptions Whirlpool Corporation v. Registrar of Trade Marks, Mumbai Supreme Court of India | (1998) 8 SCC 1 | Justice S.P. Bharucha
Held that the alternative remedy rule is not an absolute bar to a writ petition. HC can entertain a writ even when an alternative remedy exists in three situations: (1) Writ filed for enforcement of fundamental rights; (2) Violation of principles of natural justice; (3) Impugned order is wholly without jurisdiction or lacks fundamental judicial propriety. This judgment is routinely cited whenever respondents raise the alternative remedy objection in a writ petition.
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Landmark — PIL & Sexual Harassment Guidelines Vishaka & Ors. v. State of Rajasthan & Ors. Supreme Court of India | (1997) 6 SCC 241 | Justice J.S. Verma
Landmark PIL under Article 32 — in the absence of specific legislation, SC exercised writ jurisdiction to issue binding Vishaka Guidelines on prevention of sexual harassment at the workplace. Held that Articles 14, 19, and 21 mandate a safe workplace free from sexual harassment. The Vishaka Guidelines were treated as law under Article 141 until the POSH Act 2013 was enacted. Established that courts can issue positive directions to fill legislative gaps when FRs are violated.
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Landmark — Mandatory FIR Registration by PIL Lalita Kumari v. Govt. of U.P. & Ors. Supreme Court of India | (2014) 2 SCC 1 | Constitution Bench
PIL before the SC (Article 32) resulted in a binding Constitution Bench judgment — police are mandatorily required to register FIRs for cognisable offences without preliminary enquiry. The writ petition sought enforcement of the FRs of victims whose FIR registrations were refused. SC issued nationwide directions to all state governments. Demonstrates how a PIL writ petition can produce binding directions affecting the entire country and how Art. 32 can enforce rights against systematic government inaction.
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Landmark — Privacy as Fundamental Right Justice K.S. Puttaswamy (Retd.) v. Union of India Supreme Court of India | (2017) 10 SCC 1 | Nine-Judge Bench | Decided: 24.08.2017
Nine-judge bench unanimously held that the right to privacy is a fundamental right under Article 21. Overruled ADM Jabalpur v. Shukla (1976) which had held that the right to life can be suspended during Emergency. This judgment is foundational for writ petitions challenging state surveillance, biometric data collection, and intrusions into personal life. Firmly established that fundamental rights are inalienable — no state action can override them without due process and proportionality.
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Recent — 2024 Electoral Bond Scheme Struck Down — PIL Victory Supreme Court of India | Association for Democratic Reforms v. Union of India | 2024
SC struck down the Electoral Bond Scheme as unconstitutional — violating Article 19(1)(a) right to information about political funding. Landmark PIL demonstrating the power of Article 32 writ petitions to strike down parliamentary legislation that violates fundamental rights. SC directed SBI to furnish details of all electoral bonds purchased and redeemed. One of the most significant PIL outcomes in recent years — demonstrates the ongoing relevance of writ jurisdiction as a check on executive and legislative overreach.
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Recent Developments

2023 — Delhi HC
e-Filing Expanded — WP(C) / WP(Crl) Online
Delhi HC expanded e-filing for writ petitions — advocates registered on the portal can file WP(C) and WP(Crl) electronically. Video conferencing hearings for routine matters. Physical filing still required for urgent / first-day-first-listing matters. Significantly reduces travel burden.
2017 — SC 9-Judge Bench
Privacy is FR — K.S. Puttaswamy
Nine-judge bench unanimously recognised privacy as FR under Article 21. Overruled ADM Jabalpur (1976). Foundation for all writ petitions challenging state surveillance, biometric collection, and digital privacy violations. Critical for technology-related constitutional litigation going forward.

Frequently Asked Questions

Article 226 HC writ jurisdiction: covers enforcement of fundamental rights AND any other legal rights — broader scope; against any person, authority, or government within HC's territorial jurisdiction; HC has discretion — can refuse if alternative remedy available or petition is delayed. Article 32 SC writ jurisdiction: only for enforcement of Fundamental Rights (Part III) — narrower scope; the right to move SC for FR enforcement is itself a fundamental right; covers respondents anywhere in India. Article 226 is the primary forum for most writ petitions — Article 32 is for genuine FR violations of national importance where SC intervention is warranted.

The alternative remedy rule is not absolute. Per Whirlpool Corporation v. Registrar of Trade Marks (1998 SC), HC can entertain a writ despite an alternative remedy in three situations: (1) where the petition is filed for enforcement of a fundamental right; (2) where there has been a violation of principles of natural justice; (3) where the impugned order is wholly without jurisdiction or lacks fundamental judicial propriety. Also — if the alternative remedy is inadequate, illusory, or would cause irreparable harm before it can be availed — HC can intervene directly.

A Public Interest Litigation is a writ petition filed in the public interest — by any bona fide person on behalf of disadvantaged groups or for issues of public concern, even without a direct personal interest. Any citizen can file in the HC (Article 226) or SC (Article 32) for environmental matters, rights of prisoners, bonded labour, child labour, corruption, road safety, public health, electoral integrity etc. Bandhua Mukti Morcha (1984): even a letter or postcard can be treated as PIL. However — PILs must be genuinely in public interest. Frivolous PILs are dismissed with heavy costs (₹1-5 lakh in recent SC orders).

There is no fixed statutory limitation period for writ petitions under Article 226 unlike civil suits. However, courts apply the doctrine of laches — unexplained, unreasonable delay can lead to dismissal even if the writ is otherwise maintainable. Courts expect: prompt filing when the cause of action arises, satisfactory explanation for any delay, and no prejudice to the respondent from the delay. For habeas corpus — can be filed at any time during the detention. For service matters — courts expect relatively prompt filing. Practical rule: file as soon as possible after the impugned action — delay weakens the case significantly.

Yes — this is one of the most common uses of writ jurisdiction. Challenge to FIR or criminal proceedings is done by filing a petition under Section 528 BNSS (formerly S.482 CrPC) / WP(Crl) before the HC. Grounds for quashing: allegations do not constitute an offence, FIR is filed mala fide or for personal vendetta, matter is purely civil in nature, or parties have settled. The Bhajan Lal categories (1992 SC) provide the standard test. In matrimonial cases — S.498A / S.85 BNS FIR quashing petitions are very frequently filed. The HC can also stay the investigation, stay arrest, or quash the chargesheet and cognisance.

HC can grant wide-ranging reliefs: (1) Issue the specific writ — mandamus directing action, certiorari quashing order, habeas corpus releasing detenu, prohibition stopping excess, quo warranto ousting illegal officeholder; (2) Interim relief — stay of impugned order, injunction, status quo — pending final disposal; (3) Compensation for violation of fundamental rights (under Article 21); (4) Directions for CBI / SIT investigation; (5) Structural directions in PIL — continuing mandamus monitoring compliance; (6) Declaration that a law or order is unconstitutional. HC can also decline relief in its discretion — even if a technical case is made — if the equities are against the petitioner (unclean hands).

Generally no — writ jurisdiction under Article 226 is against the State, government, public authorities, statutory bodies, and persons performing public duties. A purely private employer performing no public function cannot ordinarily be a writ respondent — the remedy is a civil suit or labour/industrial dispute. Exceptions: if the employer is a statutory body, nationalised bank, public sector undertaking, university with statutory status, or is performing a public function — a writ against unfair termination may be maintainable. SC in Ramana Dayaram Shetty (1979): entities performing public duties can be respondents even if technically private.

A Revision Petition is a statutory remedy — filed against the order of an inferior court before a superior court within the court hierarchy (CPC S.115 for civil, BNSS S.438 for criminal revision). A Writ Petition under Article 226 is a constitutional remedy directly before the HC — not confined to the court hierarchy and available against any authority. Key differences: revision has a defined statutory scope; writ jurisdiction is broader and supervisory. A writ petition may be filed even when revision is available — if FRs are violated or jurisdictional excess is involved. Courts sometimes convert a revision petition into a writ petition to do complete justice.

Non-compliance with an HC writ order is civil contempt under Section 2(b) of the Contempt of Courts Act, 1971. The petitioner can file a contempt petition before the same bench. If contempt is proved — the HC can sentence the contemner (the disobeying officer) to: simple imprisonment up to 6 months, fine up to ₹2,000, or both. The HC can also direct the officer to perform the direction under threat of personal consequences. In practice — the threat of contempt is usually sufficient to ensure compliance. Particularly effective against government officers who tend to ignore HC orders.

Yes — Delhi HC has jurisdiction over Central Government authorities and departments that are located in Delhi or whose cause of action arose in Delhi. Since most Central Government ministries, departments, and regulatory authorities have their principal offices in New Delhi — Delhi HC is the primary forum for writ petitions against the Union of India. For service matters of Central Government employees — the Central Administrative Tribunal (CAT), New Delhi bench, has exclusive original jurisdiction — writ to Delhi HC only after CAT order (L. Chandra Kumar 1997 SC). For constitutional challenges to central legislation — Delhi HC or directly SC under Article 32.

Test Your Knowledge — Writ Petitions Quiz

⚖️ Writ Petitions & High Court — 10 Questions

Key Legal Terms

Article 226 — HC Writ
Constitutional power of every HC to issue writs against any person, authority, or government — for enforcement of FRs and any other legal right. Broader than Article 32. Primary forum for most writ petitions in India. HC has discretion — can refuse on alternative remedy, delay, or laches.
Mandamus
"We Command" — directs a public authority to perform a public duty it has failed to perform. Most common writ. Requires: prior demand and refusal, public legal duty, and petitioner's legal right to performance. Cannot issue against purely private persons or discretionary decisions.
Certiorari
"To be certified" — quashes completed order of inferior court / quasi-judicial authority when it acted without jurisdiction, in excess of jurisdiction, violated natural justice, or committed manifest error of law on the face of the record. Post-event corrective remedy.
Habeas Corpus
"You have the body" — most powerful personal liberty writ. Secures release from illegal / unlawful detention. Anyone can file — not just the detainee. Authority must produce the person and justify detention. If illegal — immediate release ordered. K.S. Puttaswamy (2017) strengthened personal liberty protections.
Alternative Remedy Doctrine
HC will ordinarily not entertain a writ if an adequate statutory alternative remedy exists and has not been exhausted. Three exceptions per Whirlpool (1998 SC): fundamental right violation, natural justice breach, or jurisdictional excess. Not an absolute bar — courts exercise discretion.
PIL — Public Interest Litigation
Writ petition filed in public interest — any bona fide person can file without direct personal interest. Bandhua Mukti Morcha (1984): epistolary jurisdiction — a letter can become PIL. Frivolous PILs attract heavy costs. Courts now scrutinise admissibility strictly — genuine public interest must be shown.
Locus Standi
Legal standing to file a petition — petitioner must show a sufficient interest. In ordinary writs: personal legal right affected. In PIL: relaxed — any bona fide person acting for public interest qualifies. Personal interest disguised as public interest is rejected and penalised with costs.
Quo Warranto
"By what authority" — challenges a person's legal right to hold a public office. Applies only to public offices — not private positions. Anyone can file. Court can direct the person to vacate the public office. Less common than mandamus or certiorari — typically used for challenging statutory appointments.

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