Correct Option (d):
Justice P. N. Bhagwati served as the Chief Justice of India from July 1985 to December 1986. He is widely recognized for pioneering the concept of Public Interest Litigation (PIL) in the Indian judicial system. Under his tenure, the Supreme Court adopted a liberal interpretation of the principle of locus standi, enabling public-spirited individuals and organizations to file petitions on behalf of those who were unable to approach the courts themselves. This initiative significantly expanded access to justice for marginalized sections of society and allowed the judiciary to address a broader range of social, environmental, and human rights issues.
Incorrect Options:
- M. Hidayatullah: He served as the Chief Justice of India from 1968 to 1970. This period predates the introduction and development of Public Interest Litigation in India.
- A. M. Ahmadi: He held the office of Chief Justice of India from 1994 to 1997. By this time, Public Interest Litigation was already a well-established mechanism within the Indian judiciary.
- A. S. Anand: He served as the Chief Justice of India from 1998 to 2001. His tenure was significantly after the formative period of Public Interest Litigation.