Public interest litigation limits: internal trust disputes and vague fundamental rights claims were held insufficient for Article 32 intervention.

A petition under Article 32 was held not maintainable as a public interest litigation because the dispute concerned internal management issues of a public trust and was essentially an inter se family dispute. The alleged violations of Articles 21, 49 and 51A(f) were found too vague, indirect and remote to show a direct invasion of fundamental rights of the petitioners or the public at large, so no enforceable constitutional breach was made out. The matter was considered more appropriately addressed under sections 37 and 38 of the Rajasthan Public Trust Act, 1959, broadly corresponding to sections 91 and 92 of the Code of Civil Procedure, rather than through PIL.

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Issues: Whether the petition under Article 32 of the Constitution was maintainable as a public interest litigation, and whether the allegations disclosed breach of fundamental rights warranting constitutional intervention.

Analysis: The petition arose out of internal disputes concerning the management of a public trust and the allegations were found to be essentially inter se disputes among members of an erstwhile royal family. The asserted violations of Articles 21, 49 and 51A(f) were held to be too vague, indirect and remote to establish a direct invasion of fundamental rights of the petitioners or of the public at large. The dispute was considered more appropriately amenable to proceedings under sections 37 and 38 of the Rajasthan Public Trust Act, 1959, corresponding broadly to sections 91 and 92 of the Code of Civil Procedure, 1908. The invocation of public interest litigation was therefore treated as an attempt to advance private grievances rather than a genuine public cause.

Conclusion: The petition under Article 32 was not maintainable and no enforceable fundamental right breach was made out.

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