Locus standi in certiorari requires a legal grievance; mere commercial loss from lawful competition is insufficient.

A rival cinema proprietor could not maintain certiorari under Article 226 against a no-objection certificate issued under the Bombay cinema regulatory scheme because standing depends on a legal right, legally protected interest, or special statutory interest. The scheme gave only a limited right to object on notice and did not confer a substantive right to block lawful competition. Since the applicant did not object under the prescribed procedure, belonged to no specially protected class, and showed no infringement of a legal right, his complaint amounted only to commercial loss from competition, which is damnum sine injuria. He was therefore not a person aggrieved and lacked locus standi to challenge the grant.

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Issues: Whether a rival cinema proprietor had locus standi to invoke certiorari under Article 226 to challenge a no-objection certificate granted under the Bombay cinema regulatory scheme.

Analysis: The expression "person aggrieved" in the context of certiorari was held to depend on the statutory setting, the nature of the interest affected, and whether the applicant had suffered a legal wrong or prejudice to a legally protected interest. A rival trader is not automatically an aggrieved person merely because another is permitted to enter the same field of business. The statutory scheme conferred only a limited right to object on notice and did not create a substantive right in a cinema proprietor to prevent lawful competition. The appellant had not lodged objections under the notice procedure, did not fall within the specially protected class contemplated by the scheme, and showed no infringement of any legal right. His complaint was only of commercial loss from competition, which is damnum sine injuria and not a legal grievance. In the exercise of certiorari jurisdiction, a stranger without a substantial and genuine legal interest cannot ordinarily maintain the challenge, absent exceptional circumstances.

Conclusion: The appellant was not a person aggrieved and had no locus standi to maintain the writ petition under Article 226.

Ratio Decidendi: For certiorari under Article 226, standing ordinarily requires a legal right, legal grievance, or a special and substantial interest recognized by law; mere commercial injury from lawful competition does not confer locus standi.

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