The main legal point established is the importance of verifying the credentials of the petitioner, ensuring substantial public interest, and discouraging petitions with personal gain or ulterior motives in public interest litigation.

1. The instant Public Interest Litigation has progressed to a considerable extent as would appear from the affidavits filed by the parties and also the orders passed from time to time thereupon.

2. One of the issue which has been raised on behalf of the Respondent State Authorities right from the outset do not seem to have seriously brought to the notice of the Court earlier or replied affirmatively by the PIL petitioner himself in any of the affidavits. This PIL with the prayer made herein concerning the implementation of the Bihar Deed Writers Licensing Rules, 1996, more specifically related to issuance of license to the deed writers in the Sub Registry Office of Rajmahal in the District of Sahibganj was raised by the PIL petitioner through the instant writ petition with categorical averments at para 2 thereof that he is a social worker. That the instant writ petition has been filed in a representative capacity in the larger public interest and there is no direct or indirect personal interest of the petitioner.

3. Respondent no. 2, 4 and 5 in their first counter affidavit dated 18.7.2016 questioned the conduct of the writ petitioner in the light of the guidelines issued by the Apex Court in the case of State of Uttaranchal v. Ballwant Singh Chaufal reported in (2010) 3 SCC 402 and The Jharkhand High Court (Public Interest Litigation) Rules, 2010. It was asserted therein that the writ petitioner's interest is involved as he is doing the work of deed writer. At para 19 they have further stated that writ petitioner has not made a clean declaration in para 2 of the writ petition and failed to disclose his interest in Sub-registry Office, Rajmahal. The writ petitioner is an advocate of Rajmahal and he is doing the work of deed writer. The certificate of the Bar Association, Sahibganj dated 16.7.2016 and a copy of the registered deed prepared by the petitioner were also enclosed as Annexure-J and K respectively. Petitioner however failed to respond to that even in his subsequent affidavit. It is further submitted on behalf of learned counsel for the Respondent State by referring to the Annexure-2 and 3 of the writ petition that in fact the brother of the petitioner Ashok Kumar Mandal S/o Uma Charan Mandal is himself a licensee deed writer under the Sub-registry Office, Rajmahal within Sahibganj. Annexure-3 also under the signature of District Sub Registrar, Sahibganj at Rajamahal shows the name of the brother of petitioner at serial no. 10 as a licensee deed writer. These relevant facts related to the credentials of the petitioner and absence of direct or indirect interest in the cause were conspicuously suppressed on the part of the petitioner. The Jharkhand High Court (Public Interest Litigation) Rules, 2010 also required the petitioner to give his full and complete details so as to reveal his/her interest, credentials, qualifications relevant for the Public Interest Litigation along with declaration that he/she has no personal interest, direct or indirect, in the subject matter of PIL.

4. In the case of State of Uttaranchal v. Balwant Singh Chaufal (supra), the Apex Court was in seisin of a PIL filed by a practicing lawyer. The Hon'ble Supreme Court in the realm of the issues raised therein had occasion to trace the origin and evolution of public interest litigation in India as emanated from realization of constitutional obligation by the Judiciary towards the vast sections of the society; poor and the marginalized sections of the society. This jurisdiction has been created and carved out by the judicial creativity and craftsmanship. The Court realized that because of extreme poverty, a large number of sections of society cannot approach the court. The fundamental rights have no meaning for them and in order to preserve and protect the fundamental rights of the marginalized sections of the society by judicial innovation; the Courts by judicial innovation and creativity started giving necessary directions and passing orders