Can an appeal dismissed as withdrawn with liberty to pursue alternative remedy serve as binding precedent on appellate practice?

The High Court of Chhattisgarh upholds its discretionary power to dismiss an appeal as withdrawn with liberty for alternative remedies—affirming existing procedure; persuasive authority for other High Courts and binding on subordinate courts in Chhattisgarh.

 

Summary

Category Data
Case Name ACQA/239/2022 of N. BHASKAR RAO Vs PADMAVATI LT. KRISHNA RAO
CNR CGHC010278892022
Date of Registration 24-09-2022
Decision Date 02-09-2025
Disposal Nature DISMISSED
Judgment Author Hon’ble Shri Justice Sanjay S. Agrawal
Court High Court Of Chhattisgarh at Bilaspur
Bench Single Judge Bench
Precedent Value Affirmation of procedural practice
Overrules / Affirms Affirms existing appellate withdrawal practice
Type of Law Procedural Law
Questions of Law Whether an appellate court may dismiss an appeal as withdrawn while granting liberty to pursue alternative remedies
Ratio Decidendi

When an appellant prays for withdrawal, the court may dismiss the appeal as withdrawn and grant liberty to seek any alternative remedy provided by law.

This exercise of discretionary power does not decide the merits of the underlying dispute but preserves the appellant’s right to approach the appropriate forum.

No further conditions or limitations were imposed, thereby reaffirming the High Court’s established practice.

Citations 2025:CGHC:44680

What’s New / What Lawyers Should Note

  • The High Court reaffirmed that an appellant’s prayer for withdrawal can be granted by dismissing the appeal as withdrawn and simultaneously granting liberty to pursue any alternative statutory or legal remedy.
  • No additional conditions are imposed when granting such withdrawal—this procedure preserves the appellant’s rights without adjudicating merits.
  • Lawyers can cite this order to secure a withdrawal-with-liberty disposal when an appeal is no longer sought, without prejudice to other remedies.

Summary of Legal Reasoning

  1. The appellant’s counsel sought withdrawal of the appeal with liberty to pursue alternative remedies.
  2. The High Court exercised its inherent/discretionary power in appellate procedure to dismiss the appeal as withdrawn.
  3. Liberty was granted to the appellant to avail any alternative remedy provided under law.
  4. No further adjudication of the merits was undertaken; the disposal purely addressed the procedural prayer.

Arguments by the Parties

Petitioner (Appellant):

  • Prayed for withdrawal of the appeal.
  • Sought liberty to avail alternative remedy as provided under law.

Respondent:

  • No appearance; no opposing submissions recorded.

Factual Background

In ACQA No. 239/2022, the appellant filed an appeal against an order of the Judicial Magistrate First Class, Durg dated 29-04-2022. At the hearing before the High Court, counsel for the appellant prayed for withdrawal of the appeal, seeking liberty to pursue any alternative remedy available under law. No further factual or substantive dispute was addressed.

Alert Indicators

  • ✔ Precedent Followed

Citations

  • 2025:CGHC:44680 (High Court of Chhattisgarh, Bilaspur Bench)

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