A petitioner with a personal stake cannot invoke PIL jurisdiction to pursue a private grievance.

The Rajasthan Petroleum Dealers Association filed a public interest writ petition under Article 226 challenging NOCs granted for petroleum retail outlets.

It alleged non-compliance with various environmental, safety, road and siting requirements, and sought cancellation of the NOCs or directions to ensure compliance.

The respondents contended that the allegations were general and unsupported by site-specific evidence of breach of a mandatory requirement.

The High Court considered the petitioner’s standing to bring the case as a PIL and the statutory framework governing NOCs.

Whether the petition, given the petitioner’s personal interest in the subject matter, satisfied the requirements of a bona fide public interest litigation.

Whether the petitioner established a specific breach of a mandatory legal requirement or other ground warranting interference with the granted NOCs under Article 226.

Under Article 226, PIL jurisdiction is intended to advance genuine public causes and must be invoked bona fide; a petition brought to vindicate a personal or private interest cannot acquire PIL status merely by raising public-interest concerns.

The Court relied on Hari Shankar Jain v. Bar Council of India, (2006) 1 SCC 580, and Ashok Kumar Pandey v. State of West Bengal, (2004) 3 SCC 349, concerning bona fide standing and the rejection of PILs used to pursue private interests.

Rules 144 and 154(2) of the Petroleum Rules, 2002 govern the NOC process and provide an appeal against refusal or cancellation of an NOC, but not against its grant; absence of such an appeal does not itself establish that a granted NOC is unlawful.

A challenge under Article 226 must independently establish a mandatory statutory breach, jurisdictional error, perversity or other legally sustainable ground.

The Court found that the material indicated the petitioner had a personal interest in the dispute, so the petition did not meet the bona fide threshold for PIL jurisdiction.

It also observed that the allegations concerning multiple guidelines and safeguards were generalized and did not establish that the particular NOCs violated an applicable mandatory statutory requirement.

Although Rule 154(2) provided no appeal against the grant of an NOC, that omission did not make the NOCs illegal; the petitioner still had to demonstrate a legally sustainable ground for writ interference.

Pending applications, if any, were also disposed of.