32] The jurisdiction in matters of public interest litigation has been created and carved out by judicial creativity and craftsmanship. In State of Uttaranchal vs. Balwant Singh Chaufal & Ors .6 , the Supreme Court has referred to evolution of public interest litigation in India. In the first phase, the public interest litigations mainly deal with protection of fundamental rights under Article 21 of the Constitution of India of marginalised groups and sections of society, who because of extreme poverty, illiteracy, ignorance, could not approach the judicial institutions. The second phase deals with cases relating to protection, preservation of ecology, environment, forests, marine life, wildlife, mountains, rivers, historical monuments etc. The third phase deals with directions issued by the court in maintaining the probity, transparency and integrity in governance. Upon detailed discussion, not only with regard to the evolution of public interest litigations and its various facets, the legal position in other judicial systems, namely, USA, UK, Australia and South Africa, the impact of public interest litigation on neighbouring countries like Pakistan, Sri Lanka, Nepal, the Supreme Court was constrained to advert to and deal with the
