Can a Writ Petition Be Dismissed as Infructuous by Efflux of Time When No Live Relief Remains?

The Uttarakhand High Court upholds the established principle that writ petitions lacking any surviving relief must be dismissed as infructuous; this decision reaffirms binding authority on courts to avoid adjudicating moot controversies.

 

Summary

Category Data
Case Name WPSB/149/2020 of AJAY SHARMA Vs INDIAN INSTITUTE OF TECHNOLOGY ROORKEE
CNR UKHC010058372020
Date of Registration 02-07-2020
Decision Date 18-08-2025
Disposal Nature DISMISSED AS INFRUCTUOUS
Judgment Author Hon’ble Mr. Justice Ashish Naithani; Hon’ble Mr. Justice Manoj Kumar Tiwari
Court High Court of Uttarakhand
Bench Hon’ble Mr. Justice Manoj Kumar Tiwari and Hon’ble Mr. Justice Ashish Naithani
Precedent Value Binding Authority
Overrules / Affirms Affirms
Type of Law Writ Jurisdiction under Article 226
Questions of Law Whether a writ petition with no surviving relief can be dismissed as infructuous due to efflux of time.
Ratio Decidendi The Division Bench observed that both parties were unanimous that the reliefs claimed by the petitioner no longer survived. In such circumstances, the writ petition had become infructuous by efflux of time. The High Court, therefore, dismissed the petition without delving into its merits, reaffirming the principle that courts should not decide abstract or moot controversies.
Citations 2025:UHC:7242-DB

Practical Impact

Category Impact
Binding On All subordinate courts
Persuasive For Other High Courts
Follows Established practice on dismissal of moot petitions

What’s New / What Lawyers Should Note

  • The High Court reiterated that if no live relief remains, the petition is to be dismissed as infructuous without adjudicating merits.
  • Unanimity between petitioner and respondent on mootness suffices for summary dismissal.
  • This decision can be cited to resist motions seeking continuance of adjudication when reliefs have lapsed.

Summary of Legal Reasoning

  1. Parties’ Consensus: Learned counsel for both sides agreed that the petitioner’s claimed reliefs no longer subsist.
  2. Mootness Principle: The court applied the established principle that courts will not entertain petitions which have become infructuous by efflux of time.
  3. Summary Disposal: Absent any live controversy, the petition was dismissed summarily without considering underlying merits.

Arguments by the Parties

Petitioner

  • The reliefs originally sought are no longer available.

Respondent

  • Concurred that no live relief survives and the petition is moot.

Factual Background

Ajay Sharma filed WPSB No. 149 of 2020 in the Uttarakhand High Court against the Indian Institute of Technology Roorkee. By the decision date, the substantive relief sought by the petitioner had lapsed. Both parties agreed that no effective relief remained, prompting the Court to dismiss the petition as infructuous.

Statutory Analysis

No specific statutes were interpreted; the decision rests on the inherent power of the High Court under Article 226 to refuse adjudication of moot or infructuous petitions.

Alert Indicators

  • ✔ Precedent Followed

Citations

  • 2025:UHC:7242-DB
  • CNR UKHC010058372020

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