The Delhi High Court dismissed a PIL challenging the government's failure to establish a memorial for the Indian National Army, despite earlier official commitments. The court held that no fundamental right under Articles 14 or 21 of the Constitution is violated when a government fails to honour a policy promise. A government's pledge to build a memorial does not create an enforceable constitutional entitlement that courts can compel through PIL jurisdiction.

This ruling sharpens a critical boundary in PIL jurisprudence: the distinction between a government's policy promise and a constitutionally enforceable fundamental right. The court's reasoning rests on a well-established principle — Article 21 protects the right to life and personal liberty, and Article 14 guarantees equality before law, but neither provision converts every government commitment into a justiciable right. A memorial is a policy decision within the executive's discretionary domain; courts cannot substitute their judgment for executive inaction on such matters unless a specific legal right is traceable to a statute or constitutional provision.

The PIL route is available to enforce fundamental rights or expose a breach of a constitutional or statutory duty — it is not available to compel the executive to fulfil political or policy promises. This case reinforces the locus standi test for PILs: the petitioner must identify a specific right that has been violated, not merely demonstrate that a government pledge was broken. CLAT PG examiners frequently test this distinction — when is PIL maintainable, and on what grounds can a court refuse to entertain it? The answer here is doctrinal: policy discretion is insulated from PIL challenge unless the decision is arbitrary, discriminatory, or violates a positive statutory duty. The INA memorial case provides a clean, recent example of this principle in action.