The Supreme Court, in a 2010 judgment, provided its own history of PIL, broadly dividing public interest litigation in India into three phases.

From ‘poverty’ to ‘environment’ to ‘governance’: this is the trajectory of PIL that the Indian Supreme Court itself confesses to. Sudipta Kaviraj has written as to how the decline of institutional spaces with Mrs Gandhi's more personalized politics made possible a new irresponsibility of ideology with baffling shifts of emphasis, the most spectacular of these being that ‘fertility and not poverty became the major obstacle to Indian development’ during the Emergency. PIL, too, with its lack of institutional grounding and close identification with specific judges, has been prone to these sorts of wild fluctuations in ideology. The most celebrated of these has been the change of focus from poverty in its first phase in the early 1980s to ‘bourgeois environmentalism’ from the mid-1990s. It is the inherent instability of populism in both instances that allowed such a fundamental shift in priorities to take place.

This change in priorities in PIL cases has not gone unlamented. There has been a significant literature criticizing it, especially the dislodging of the poor from the position of PIL's foremost discursive constituency.