Journal of African Development

Public Interest Litigation (PIL) has emerged as an important legal mechanism for promoting social justice and ensuring the protection of constitutional rights, particularly for marginalized communities. This paper undertakes a comparative analysis of the development and functioning of PIL in India and South Africa. It examines the historical emergence of PIL, the evolution of locus standi, the nature of issues addressed, the procedures for initiating PIL, and the remedies granted by courts. The study highlights that while the Indian model evolved mainly through judicial activism and procedural flexibility, the South African model is constitutionally entrenched and operates within a more structured framework. The comparison demonstrates how different institutional approaches can shape the role of courts in advancing access to justice and governmental accountability..