Can a Public Interest Litigation Be Withdrawn After Registration Without Any Judicial Pronouncement on Merits? (Clarification regarding the fate of PILs withdrawn by petitioners; No new law created, reinforces status quo; Dismissal as withdrawn – No precedential value as to merits)

Where a Public Interest Litigation (PIL) is withdrawn by the petitioner without any arguments on merits, the court dismisses the matter as withdrawn, without delivering any substantive ruling on the legal questions raised. This case reaffirms that withdrawal does not create binding precedent or alter existing legal principles, and such orders have no precedential effect for future disputes.

 

Summary

Category Data
Case Name WPC/3467/2023 of LALCHAND MAHTO Vs THE STATE OF JHARKHAND
CNR JHHC010231052023
Date of Registration 05-07-2023
Decision Date 17-10-2025
Disposal Nature Dismissed as Withdrawn
Judgment Author Tarlok Singh Chauhan, C.J. and Rajesh Shankar, J.
Court High Court of Jharkhand
Bench Division Bench: Hon’ble the Chief Justice, Hon’ble Mr. Justice Rajesh Shankar
Precedent Value None – No merits decided; order has no precedential effect

Practical Impact

Category Impact
Binding On Not binding on any courts; no legal principle established.
Persuasive For Not persuasive; does not contain reasons or ratio on merits.

What’s New / What Lawyers Should Note

  • Withdrawal of a PIL before adjudication on merits results in a dismissal as withdrawn, without determination of any legal questions.
  • Such orders have no precedential value and cannot be cited as authority in future matters.
  • No legal clarification or substantive judicial reasoning is provided when a petition is dismissed as withdrawn at the petitioner’s request.
  • Lawyers representing petitioners in PILs should be aware that withdrawal leaves all issues open and undecided for future litigation.

Summary of Legal Reasoning

  • The court merely recorded the statement of the petitioner’s counsel seeking permission to withdraw the writ petition (PIL).
  • Based on the request, the court dismissed the writ petition as withdrawn.
  • There was no judicial consideration or determination of any questions of law or facts presented in the petition.
  • No legal reasoning, statutory interpretation, or reliance on precedent was entered into by the court.

Arguments by the Parties

Petitioner

  • Counsel stated he is under instructions to withdraw the W.P. (PIL).

Respondent

No arguments by the respondents are recorded in the order.

Factual Background

The petitioner, Lalchand Mahto, aged about 72 years, filed a public interest litigation (PIL) (W.P.(PIL) No. 3467 of 2023) before the High Court of Jharkhand at Ranchi. During the proceedings, the petitioner’s counsel sought leave to withdraw the PIL. There is no mention within the judgment of the underlying facts, legal issues, or events that led to the filing or withdrawal of the petition.

Statutory Analysis

  • No statutory provisions were discussed or interpreted in this judgment.
  • No statutory analysis was undertaken as the matter was dismissed on withdrawal.

Dissenting / Concurring Opinion Summary

There are no dissenting or concurring opinions; the order is unanimous.

Procedural Innovations

  • No new procedural norms or innovations were set by the Court in this judgment.
  • The order follows the standard practice of permitting withdrawal of writ petitions upon the petitioner’s request.

Alert Indicators

  • ✔ Precedent Followed – The Court’s approach is in line with existing practice, reaffirming that withdrawal of petitions before adjudication leaves questions open and unsettled.

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