Step 1: Concept
Stability of substituted ammonium ions in aqueous solution depends on solvation.
Step 2: Meaning
Solvation (hydration) by water molecules stabilizes the cation through hydrogen bonding with available H atoms.
Step 3: Analysis
- $NH_{4}^{+}$ has 4 H-atoms for H-bonding.
- $R_{3}NH^{+}$ has only 1 H-atom for H-bonding.
- Fewer H-atoms result in less extensive solvation and lower stability in water.
Step 4: Conclusion
Hence, $R_{3}NH^{+}$ is the least stable in aqueous medium.
Final Answer: (D)