Can a High Court Dismiss a Writ Petition as Infructuous When the Petitioner’s Grievance is Already Redressed?

Clarifying the Court’s Approach to Writ Petitions Rendered Infructuous and Its Reaffirmation of Established Procedure

 

Summary

Category Data
Case Name WPMB/900/2025 of MS PRAMOD KUMAR GOVT CONTRACTOR AND GENERAL ORDER SUPPLIER Vs STATE OF UTTARAKHAND
CNR UKHC010167042025
Date of Registration 16-10-2025
Decision Date 28-10-2025
Disposal Nature DISPOSED
Judgment Author HON’BLE MR. JUSTICE RAVINDRA MAITHANI, HON’BLE MR. JUSTICE ALOK MAHRA
Court High Court of Uttarakhand
Bench Division Bench – HON’BLE MR. JUSTICE RAVINDRA MAITHANI, HON’BLE MR. JUSTICE ALOK MAHRA
Precedent Value Binding for similar issues before the Uttarakhand High Court and its subordinate courts
Type of Law Procedural Law – Writ Jurisdiction
Ratio Decidendi

The Court held that when the petitioner’s grievance stands redressed during the pendency of a writ petition, it is appropriate to dismiss the petition as infructuous.

The petitioner, via counsel, stated that no dispute survives. The High Court, therefore, disposed of the matter accordingly, underscoring that writ jurisdiction is not invoked for academic or hypothetical issues once relief is obtained.

Facts as Summarised by the Court The petitioner’s counsel informed the Court at the outset that the grievance in the writ petition stands redressed, and therefore, the writ petition is now infructuous.

Practical Impact

Category Impact
Binding On All subordinate courts and authorities within the jurisdiction of the Uttarakhand High Court.
Persuasive For Other High Courts in India may consider the procedural approach adopted.

What’s New / What Lawyers Should Note

  • Reiterates that writ petitions rendered infructuous due to redressal of grievances should be dismissed as such.
  • Counsel for the petitioner may make a submission at the outset regarding the infructuous nature of the writ.
  • The Court will not proceed to examine the merits of a petition that has become infructuous during its pendency.

Summary of Legal Reasoning

  • The petitioner’s counsel submitted at the very beginning of the hearing that the issues raised in the petition were moot as the grievance had been resolved.
  • The Court, upon being satisfied with the submission and there being no remaining dispute, dismissed the writ petition as infructuous.
  • The judgment reflects the principle that courts do not decide academic or hypothetical disputes when the real controversy has ceased to exist between the parties.

Arguments by the Parties

Petitioner

  • Informed the Court that the grievance which formed the subject matter of the writ petition has already been redressed and requested dismissal of the petition as infructuous.

State

  • Represented by Additional Chief Standing Counsel; the State’s stance was not separately recorded as the petitioner’s submission resolved the issue.

Respondent Nos. 2 and 3

  • Represented by counsel; no separate submissions recorded, as the petition was disposed of as infructuous at the petitioner’s request.

Factual Background

The writ petitioner approached the Uttarakhand High Court with a grievance, filing WPMB No.900 of 2025. During the pendency of proceedings, the petitioner’s counsel informed the Court that the grievance no longer existed as it had already been addressed. As a result, the writ petition was considered to have become infructuous and was dismissed accordingly.

Statutory Analysis

The judgment is procedural in nature and does not set out statutory interpretation. It affirms the established practice under writ jurisdiction that courts do not entertain petitions where the original grievance stands redressed before adjudication.

Dissenting / Concurring Opinion Summary

No dissenting or concurring opinions were recorded in this case.

Alert Indicators

  • ✔ Precedent Followed – Existing procedural law and practice were affirmed regarding infructuous writ petitions.

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