The Andhra Pradesh High Court held that when the cause for approaching the court in a writ petition ceases to exist due to subsequent developments, the petition is to be dismissed as infructuous. This decision follows and applies established legal precedent without introducing new law, and has binding value for subordinate courts within Andhra Pradesh in public employment and service matters.
Summary
| Category | Data |
|---|---|
| Case Name | WP/22767/2016 of Pendyala Subrahmanyam Vs The Andhra Pradesh Eastern Power Distribution Company Ltd., CNR APHC010839182016 |
| Date of Registration | 12-07-2016 |
| Decision Date | 16-10-2025 |
| Disposal Nature | CLOSED NO COSTS |
| Judgment Author | Maheswara Rao Kuncheam |
| Court | High Court of Andhra Pradesh |
| Precedent Value | Binding authority within jurisdiction of Andhra Pradesh High Court |
| Type of Law | Service Law / Constitutional Law (Articles 14, 16, 21, and administrative service regulations) |
| Questions of Law | Whether a writ petition is to be dismissed as infructuous when the relief sought by the petitioner has been granted due to subsequent events before adjudication. |
| Ratio Decidendi | When the petitioner obtains the relief sought through subsequent events during the pendency of a writ petition, the court will record the factual position and dismiss the petition as infructuous. There is no adjudication on merits. No order as to costs will typically be made. This approach upholds judicial economy and avoids unnecessary pronouncements on hypothetical matters. |
| Facts as Summarised by the Court | The petitioner, having already been promoted to the post in question subsequent to filing the writ, had his counsel and the respondent’s counsel submit jointly that the cause of action had been redressed. The court consequently dismissed the petition as infructuous. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts in Andhra Pradesh; all original jurisdiction matters before the High Court |
| Persuasive For | Other High Courts when dealing with similar public employment disputes |
What’s New / What Lawyers Should Note
- The court reaffirms that if a petitioner secures the relief sought independently or by subsequent administrative action during litigation, the writ petition may be dismissed as infructuous.
- There is no need for the court to decide the merits of the dispute when the cause for litigation no longer exists.
- There will generally be no order as to costs in such situations.
- Lawyers should promptly inform the court if the relief has been granted during pendency, to ensure judicial time is not wasted and to record closure efficiently.
Summary of Legal Reasoning
- The Hon’ble Justice Maheswara Rao Kuncheam recorded the joint statement by counsels for both parties that the petitioner was already promoted to the post of Sub-Engineer, satisfying the cause of action for filing the writ.
- The court adopted the settled principle that writ petitions become infructuous when the grievance that gave rise to the petition has been redressed while the matter is pending.
- As the purpose of the petition no longer survived, the court declined to adjudicate on the merits.
- The petition was dismissed as infructuous, with no costs, and all pending applications stood closed.
Arguments by the Parties
Petitioner
- The petitioner’s counsel submitted that the petitioner has already been promoted to the Sub-Engineer post, making the original prayer fulfilled.
Respondent
- The respondent’s counsel (for APEPDCL) confirmed the petitioner’s promotion and agreed that the cause for the writ had ceased to exist.
Factual Background
The writ petition was filed by an employee seeking parity in promotion as Sub-Engineer, challenging the promotion of juniors over him under the APSEB Employees Service Regulations and claiming violation of constitutional rights. During the pendency of the proceedings, the petitioner was promoted to the desired post. At the time of hearing, both sides informed the court of this development, thus removing the basis of the original dispute.
Statutory Analysis
- The original writ invoked Articles 14, 16, and 21 of the Constitution of India, as well as APSEB Employees Service Regulations Part II.
- No interpretation of these provisions was required or undertaken, as the relief had already been rendered academic due to subsequent events.
Dissenting / Concurring Opinion Summary
There were no dissenting or concurring opinions in this judgment.
Procedural Innovations
None recorded in the judgment. Standard procedure was followed: upon fulfillment of the writ’s cause, the petition was dismissed as infructuous.
Alert Indicators
- ✔ Precedent Followed – The judgment adheres to and applies established legal principles regarding infructuous petitions due to subsequent relief.