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Issues: Whether a third party had locus standi under Article 32 of the Constitution of India to maintain a public interest petition seeking conversion of a death sentence into life imprisonment and to question the conviction and sentence of condemned prisoners.
Analysis: The petition was examined against the settled limits of public interest litigation. The governing principle applied was that a PIL must rest on real public interest and bona fide concern, and not on private motive, publicity, or oblique considerations. The Court treated with caution attempts by strangers or busybodies to invoke extraordinary constitutional jurisdiction on behalf of others. It also noted that ordinarily the aggrieved person must seek redress personally, and a third party can intervene only where the law recognises a disability such as minority or insanity, as reflected in the provisions of the Code of Criminal Procedure dealing with representation through a next friend. No legal disability of that kind was shown. The petitioner did not establish any personal right violated, any genuine public injury, or any basis to challenge the criminal process on behalf of the condemned prisoners.
Conclusion: The petition was not maintainable under Article 32 and was rejected for want of locus standi.
Ratio Decidendi: A stranger cannot invoke Article 32 to challenge another person's conviction or sentence unless the affected person is under a legally recognised disability that permits representation through a next friend.