High Court Reaffirms That Satisfaction of Relief and Express Withdrawal Renders a Writ Petition Infructuous, Binding on Subordinate Courts of Rajasthan
Summary
| Category | Data |
|---|---|
| Case Name | CW/16229/2017 of SMT ANJU BALA SHARMA Vs STATE OF RAJ AND ORS |
| CNR | RJHC020581412017 |
| Date of Registration | 16-09-2017 |
| Decision Date | 25-08-2025 |
| Disposal Nature | DISMISSED |
| Judgment Author | Mahendar Kumar Goyal |
| Court | High Court of Rajasthan, Bench at Jaipur |
| Bench | Single Judge Bench |
| Precedent Value | Binding on subordinate courts of Rajasthan |
| Overrules / Affirms | Affirms existing practice |
| Type of Law | Civil writ jurisdiction |
| Questions of Law | Whether a writ petition becomes infructuous when the relief is satisfied and petitioner withdraws? |
| Ratio Decidendi |
|
| Facts as Summarised by the Court | The petitioner was paid ₹1,00,000 pursuant to the court’s order dated 20-08-2025; by a receipt dated 22-08-2025 she stated she did not wish to prosecute further. |
| Citations | [2025:RJ-JP:33433] |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts of Rajasthan |
| Persuasive For | Other High Courts seeking guidance on dismissing infructuous petitions |
What’s New / What Lawyers Should Note
- Confirms that monitoring the filing of a cost-receipt and withdrawal statement is sufficient to render a writ petition infructuous.
- Reinforces that once the court-ordered relief is fully complied with, the petition does not survive for further adjudication.
- Highlights the utility of inherent powers to clear cases where no live controversy remains.
Summary of Legal Reasoning
- The Court had earlier directed payment of ₹1,00,000 as cost on 20-08-2025.
- On 22-08-2025, the petitioner produced a receipt and expressly renounced further prosecution.
- The Court observed that with the relief satisfied and no live dispute, the writ petition stood rendered infructuous.
- Invoking its inherent powers and in the interests of judicial economy, the Court dismissed the petition.
Factual Background
Smt. Anju Bala Sharma filed a writ petition challenging certain official action in the education department. The High Court directed payment of ₹1,00,000 as cost to the petitioner. Upon receipt, the petitioner submitted a formal acknowledgment dated 22-08-2025 and declared she did not wish to pursue the litigation further. Consequently, the Court held there was no live controversy and dismissed the petition as infructuous.
Alert Indicators
- ✔ Precedent Followed – The judgment affirms the established practice of dismissing petitions once relief is obtained and withdrawn.
Citations
- [2025:RJ-JP:33433]