Around 2013, in what context was the term 'judicial overreach' commonly used?

Question and options

1. The powers of judiciary to bring to justice even the citizens of India outside India, for instance through the extra-territorial operation of the Bharatiya Nyaya Sanhita, 2023 (formerly the Indian Penal Code).
2. The expanding realm of public interest litigation and judicial activism in India.
3. The jurisdiction of judiciary on MNCs, as seen in the Bhopal gas leak case where the subsidiary of a company incorporated in the United States had to submit to the jurisdiction of courts in India.
4. The High Court in a state of the union hearing a matter falling in the territorial jurisdiction of another state's High Court