The High Court reaffirms that, where a tribunal’s order awarding monetary benefits has been executed and the decree marked satisfied, a subsequent writ under Article 226 holds no live controversy and must be dismissed—upholding established procedural precedent and binding on subordinate courts in Rajasthan.
Summary
| Category | Data |
|---|---|
| Case Name | CW/7533/2003 of THE MANAGING COMMITTEE CHIRAWA Vs SAHI RAM AND ORS |
| CNR | RJHC020196362003 |
| Date of Registration | 09-12-2003 |
| Decision Date | 27-08-2025 |
| Disposal Nature | DISMISSED |
| Judgment Author | Mahendar Kumar Goyal |
| Court | High Court Of Rajasthan |
| Bench | Bench at Jaipur |
| Precedent Value | Reaffirms existing procedural principle |
| Overrules / Affirms | Affirms |
| Type of Law | Writ Jurisdiction under Article 226 |
| Questions of Law | Whether a writ petition challenging a tribunal’s monetary award becomes infructuous once the decree is executed and satisfied. |
| Ratio Decidendi | Once an executing court records satisfaction of a decree passed upon a tribunal’s award, no live dispute remains for adjudication under Article 226, rendering any writ petition infructuous and liable to dismissal. |
| Logic / Jurisprudence / Authorities Relied Upon by the Court | The court applied the principle of infructuosity of writ petitions where execution is complete; relied on the execution court’s certificate of satisfaction. |
| Facts as Summarised by the Court | The petition impugned an August 2003 tribunal order awarding monetary benefits. Execution Court (Case No.9/2007) held the decree satisfied on payment by the petitioner on February 11, 2017. |
| Citations |
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What’s New / What Lawyers Should Note
- A writ petition against a tribunal’s monetary award becomes infructuous and is liable to dismissal once the decree is executed and formally satisfied.
- The execution court’s certified satisfaction extinguishes any live controversy for the purposes of Article 226.
Summary of Legal Reasoning
- The writ challenged the Rajasthan Non-Government Educational Institutions Tribunal’s order dated 16 August 2003, which awarded monetary benefits to Respondent No.1.
- In Execution Case No. 9/2007, the Civil Judge, Chirawa, by order dated 11 February 2017, recorded that the decree had been satisfied on payment by the petitioner.
- With payment made and the decree marked satisfied, no live controversy remained to be adjudicated under Article 226.
- The High Court, applying the principle of infructuosity of writ petitions, dismissed the petition and disposed of all pending applications.
Arguments by the Parties
Petitioner
- No representation appeared; no submissions recorded.
Respondent No.1
- Relied on the certified copy of the execution court’s order (11 February 2017) demonstrating satisfaction of the decree.
- Argued that the writ petition was rendered infructuous and must be dismissed.
Factual Background
The Managing Committee of Chirawa College filed a writ under Article 226 against the Rajasthan Non-Government Educational Institutions Tribunal’s August 2003 award granting librarian-clerk Sahi Ram certain monetary benefits. In Execution Case No. 9/2007, the Civil Judge, Chirawa, by order dated 11 February 2017, recorded that the decree had been satisfied upon payment by the college. With the execution complete and satisfaction recorded, the High Court found no live dispute and dismissed the writ petition as infructuous.
Alert Indicators
- ✔ Precedent Followed – Affirms the established principle that a writ petition becomes infructuous once the decree is satisfied.
Citations
- [2025:RJ-JP:34201]
- S.B. Civil Writ Petition No. 7533/2003
- CNR RJHC020196362003