【正文】 the entire population, on the basis of society39。s full participation in the process of development and a fair distribution of its benefits. This allows a person to growth in a healthy environment. Thus, the right to development must imply that there has to be respect for all human rights in the development process, be it economic, social, cultural, civil or political. As right to development is important to the public, a flexible rule on standing in this proceeding is necessary so as to provide an easier channel for the public to get access to justice. Hence, locus standi should be given to an organisation or a group of individuals, who have no personal gain or private motive to take an action for any wrongful act of the authority to see that public injury does not take place and avoid acts or omissions that violate the constitution or the law. This is line with the mandate of this litigation, ., to promote public interest which states that violations of legal or constitutional rights of a large number of poor, downtrodden, ignorant, socially or economicallydisadvantaged persons should not go unredressed. For that reason, it is the duty of the court to intervene if there is any plaint by the public against the authority for any wrongful act that violates the constitution or law. Nevertheless, the court must take precautions against the public that they approach the court with no personal interest to ensure that there is no abuse of the court39。s process. As far as Malaysia is concerned its public law behavioral attitude on the development of public interest litigation is not well develop. The rigid rule on locus standi has discouraged the progressive move of public interest litigation cases. Further, with unclear definition on who is an `adversely affected person39。under Order 53 rule 2(4) of the Rules of Court 2012 it adds on to the slow movement of public interest in Malaysia. The inactive behavior of the Malaysian apex court has affected the growth of public interest litigation. As a result, an injustice occurred. For this reason, it is vital to find new ways of getting access to justice for violation of rights, in particular violation of fundamental rights. Hence, it is necessary to carry out a parative study on the jurisprudence and legal framework in other mon law countries that are progressive and dynamic such as India, South Africa and Hong Kong. This study aims to establish the need for a progressive jurisprudence, constitutional and legal framework on public interest litigation to provide wider access to justice. Based on a qualitative research method, it will examine the availability of the public law jurisprudence and legal framework of the progressive system in India, Hong Kong, South Africa and United Kingdom on access to justice. The role of the courts and the current jurisprudence applied by the countries mentioned will be examined to confirm that an active behavioral of the judiciary and legal framers are capable of providing an access to justice to the general public for public purposes. The oute of the study is the creation of a proposed model on the jurisprudence and legal framework on the enforcement of public interest litigation in the new millennium.2. Public interest litigation Position in MalaysiaPublic interest litigation has bee an essential tool in protecting the public. Due to the flexible rules on standing this form of litigation has bee a popular instrument to check upon unlawful or unconstitutional actions or arbitrary act of the authority. Such approach allows the public who is not a busy body and with no personal interest to a plaint against the authority against those actions. The flexible procedure provided under this litigation could equally provide and protect the basic human rights, constitutional as well as legal to all as required by the rule of law. Hence, public interest or social action litigation could be used as an influential platform to ensure that basic human rights to be meaningful, especially to the deprived and vulnerable sections of the munity and to the public generally. The jurisprudence in this area is continuously developing so as to warrant the achievement on the great ideas of socioeconomic justice and good environment for human living. Thus, the courts have to fashion new methods and strategies for providing access to justice to a large section of the society which was deprived and vulnerable. As far as the rule of standing in Malaysia is concerned prior to the case of Lim Kit Siang there was a liberal behavioral pattern of the judiciary. Nevertheless, the situation changed, and the jurisprudence has retreat from liberal to strict approach when the Supreme Court in Lim Kit Siang took a stringent test on the rule of standing. Post Lim Kit Siang discourages the development of public interest litigation and stopped the transformation of judicial activism with far reaching changes both in nature and form of the judicial process. As a result, the rule on standing in Malaysia is unclear. Even though under Order 53, rule 2(4) Rules of Courts provides that an adversely affected person has locus standi to apply for judicial review, the question as to who is an adverselyaffected person has yet to be determined by the court. A more liberal threshold locus standi test was applied by the Court of Appeal in QSR Brands Bhd v Suruhanjaya Sekuritiamp。Anon In this case, the Court of Appeal had referred to Gouriet v Union of Post Office Workers, where Lord Wilberforce said that in applications for prerogative writs in the environment of public law enforcement, the courts have allowed the application of liberal access under a generous conception of locus standi. Hence, whether the phrase is rigidly or liberally interpreted, it all depends on the attitude of the court. Nevertheless, with different approaches taken by the Malaysian court on this matter before and after the decision of the Supreme Court in Lim Kit Siang, the