In P.N. Duda v. P. Shiv Shanker (1988), the Attorney-General and the Solicitor-General declined to act…

The Court held that where the Attorney-General or Solicitor-General refuses consent or declines to act, "their decision is not judicially reviewable", and the petitioner's remedy is to approach the Court for action under rule 3(a) of its contempt rules. Adding the law officers as respondents could not cure the lack of consent, and a private person may still bring a contempt to the Court's notice in this way.