The court clarified that when the relief sought in a writ petition (mandamus for police investigation) becomes infructuous during proceedings, the petition will be dismissed as infructuous; this upholds existing procedural precedent under Article 226. The judgment serves as binding authority on the procedural outcome within the Andhra Pradesh High Court’s jurisdiction.
Summary
| Category | Data |
|---|---|
| Case Name | WP/42431/2022 of GOSTU DAYASAGAR Vs THE STATE OF ANDHRA PRADESH |
| CNR | APHC010719182022 |
| Date of Registration | 29-12-2022 |
| Decision Date | 03-11-2025 |
| Disposal Nature | DISMISSED AS INFRUCTUOUS |
| Judgment Author | Dr. Justice Venkata Jyothirmai Pratapa |
| Court | High Court of Andhra Pradesh |
| Precedent Value | Binding within jurisdiction on procedural outcome of infructuous writs |
| Type of Law | Constitutional Law (Article 226—Writ jurisdiction) |
| Questions of Law | Effect of supervening events rendering mandamus petitions for investigation infructuous under Article 226 |
| Ratio Decidendi |
The High Court, exercising writ jurisdiction under Article 226, noted that where the prayer for a mandamus (for expeditious police investigation) becomes infructuous as per the petitioner’s own submission, the petition must be dismissed as infructuous. The court recorded the petitioner’s request for disposal on account of infructuousness and accordingly dismissed the petition without costs. This reaffirms the established procedural position regarding supervening events affecting writ relief. |
| Facts as Summarised by the Court | The petitioner sought a mandamus directing expeditious investigation and prevention of settlement pressure in a named police case. During proceedings, petitioner’s counsel submitted that the relief had become infructuous, leading to the writ’s dismissal. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | Subordinate courts within Andhra Pradesh; High Court benches hearing writs under Article 226 |
| Persuasive For | Other High Courts, especially in procedural matters concerning infructuous writ petitions |
What’s New / What Lawyers Should Note
- Reaffirms that when the relief sought in a writ petition is no longer live due to subsequent events, the writ will be dismissed as infructuous upon petitioner’s request.
- Highlights the importance of keeping the court apprised of changes affecting the necessity or justiciability of mandamus relief.
- Confirms that there is no adjudication on merits if relief is no longer required as of the date of hearing.
Summary of Legal Reasoning
- The High Court recorded the representation by the petitioners’ counsel that the writ had become infructuous.
- The court acknowledged the request and dismissed the petition as infructuous, without entering into the merits of the original prayer.
- This approach aligns with the procedural rule that courts will not decide academic or hypothetical issues once the substantive relief is no longer sought or necessary.
Arguments by the Parties
Petitioner
- Submitted that the matter had become infructuous and requested disposal of the writ petition on that ground.
Respondent
- Learned Assistant Government Pleader for Home was present; no substantive submission recorded.
Factual Background
The petitioners filed a writ under Article 226 seeking a mandamus to direct expeditious investigation into Crime No.162 of 2022 at Pamur Police Station, and to restrain police from pressurizing them to settle disputes with the 5th respondent. During the hearing, the petitioners’ counsel informed the court that the relief sought had become infructuous and requested appropriate disposal. The writ was dismissed accordingly.
Statutory Analysis
- Article 226 of the Constitution of India: Invoked by petitioners for mandamus. The judgment reiterates that relief under Article 226 will not be granted where the original dispute has become infructuous.
- No further statutory interpretations or expansions were made.
Dissenting / Concurring Opinion Summary
No dissenting or concurring opinions were noted in the judgment.
Procedural Innovations
None indicated; the court followed standard procedure in dismissing infructuous writ petitions.
Alert Indicators
- ✔ Precedent Followed – Existing law affirmed regarding procedural disposal of infructuous writ petitions.