3.
The answer is: D
Explanation
The correct option is D: Justice P. N. Bhagwati.
He is known as the father of public interest litigation (PIL) in India because of his contribution to PIL jurisprudence. He introduced the concepts of PIL and absolute liability in India, and for this reason is held, along with Justice V. R. Krishna Iyer, to be a pioneer of judicial activism in the country.
PIL refers to litigation undertaken to secure public interest and demonstrate the availability of justice to socially-disadvantaged parties. It is a relaxation on the traditional rule of locus standi, which means that even people who are not directly involved in the case may bring matters of public interest to the court.
Justice Bhagwati was Chief Justice of India from July 12, 1985, to December 20, 1986. He was also a devotee of the popular Indian guru Sathya Sai Baba, and was a member of Sathya Sai Trust till his death.