In Gambhirdan K Gadhvi Vs. State of Gujarat (2022) 5 SCC 179, the Supreme Court, referring to an earlier judgment in Retd. Armed Forces Medical Association and Ors. Vs. Union of India & Ors., (2006) 11 SCC 731, observed that strict rules of locus standi are relaxed to some extent in a quo warranto proceedings.
In Jasbhai Motibhai Desai v. Roshan Kumar, Haji Bashir Ahmed (1976) 1 SCC 671, the Supreme Court had observed thus: This Court has laid down in a number of decisions that in order to have the locus standi to invoke the extraordinary jurisdiction Under Article 226, an applicant should ordinarily be one who has a personal or individual right in the subject-matter of the application, though in the case of some of the writs like habeas corpus or quo warranto this Rule is relaxed or modified. [ Also see Ghulam Qadir vs Special Tribunal (2002) 1 SCC 33 ]