The High Court of Uttarakhand reaffirms that writ petitions that have become infructuous—such as those involving unsuccessful candidates in entrance examinations—are liable to be dismissed as infructuous at any stage. This judgment follows established precedent and clarifies that such cases need not be adjudicated on merits once the substantive relief cannot be granted. The decision is binding in Uttarakhand and persuasive elsewhere, especially in educational admission cases.
Summary
| Category | Data |
|---|---|
| Case Name | WPMS/2637/2024 of BHARTI DHINGRA Vs STATE OF UTTARAKHAND |
| CNR | UKHC010154342024 |
| Date of Registration | 26-09-2024 |
| Decision Date | 15-10-2025 |
| Disposal Nature | DISMISSED AS INFRUCTUOUS |
| Judgment Author | HON’BLE MR. JUSTICE MANOJ KUMAR TIWARI |
| Court | High Court of Uttarakhand |
| Bench | Single Judge |
| Precedent Value | Binding on Uttarakhand subordinate courts; persuasive elsewhere |
| Type of Law | Procedural/Administrative |
| Questions of Law | Whether writ petition survives once the petitioner becomes ineligible for relief due to non-qualification in entrance examination. |
| Ratio Decidendi (3–8 sentences) |
The High Court held that writ petitions become infructuous when petitioners no longer qualify for the relief sought. In the present case, since the petitioners could not qualify in the entrance examination for admission to the D.El.Ed. course, the writ petitions cease to survive. It was accepted by the counsels for the petitioners as well as by the State Counsel that no substantive relief could now be granted. The court, therefore, dismissed the petitions as infructuous without going into the merits. Interim orders, if any, were vacated. |
| Logic / Jurisprudence / Authorities Relied Upon by the Court | Based on parties’ admissions and established procedural principles regarding infructuous matters. |
| Facts as Summarised by the Court | Petitioners had challenged issues relating to admission to D.El.Ed. course, but became ineligible as they could not qualify in the entrance examination. Both petitioner and state counsel admitted that the reliefs claimed no longer survived. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts of Uttarakhand |
| Persuasive For | Other High Courts, Supreme Court (as procedural authority) |
What’s New / What Lawyers Should Note
- Reiterates that writ petitions become infructuous where petitioners no longer qualify for the relief sought, particularly in cases involving academic entrance examinations.
- Lawyers should note that upon becoming infructuous, no adjudication on merits will be undertaken.
- Interim orders in such cases will be vacated automatically upon dismissal for infructuousness.
Summary of Legal Reasoning
- Counsel for petitioners stated on record that the writ petitions had become infructuous as the petitioners could not qualify in the entrance examination for admission to the D.El.Ed. course.
- The learned State Counsel also agreed that the reliefs claimed in other writ petitions do not survive.
- On these admissions, the Court found that no effective relief could be granted and held that deciding the substantive claims was unnecessary.
- The Court disposed of the petitions as infructuous, vacating all interim orders.
Arguments by the Parties
Petitioner
- Through counsel, submitted that the writ petitions had become infructuous as the petitioners did not qualify in the entrance examination for admission to the D.El.Ed. course.
Respondent (State)
- Submitted that the relief claimed in the other writ petitions did not survive any more.
Factual Background
The petitioners had filed writ petitions challenging issues related to admission to the D.El.Ed. course. However, during proceedings, it transpired that the petitioners failed to qualify in the requisite entrance examination. Both petitioners’ counsels and the State Counsel accepted on record that no effective relief could now be granted.
Statutory Analysis
The judgment did not discuss or interpret any statutory provisions, as the disposal was procedural due to infructuousness acknowledged by the parties.
Dissenting / Concurring Opinion Summary
No dissenting or concurring opinion is recorded in this single judge decision.
Procedural Innovations
No new procedural innovations were indicated. The dismissal as infructuous follows standard court procedure upon acknowledgment by parties that no relief remains possible.
Alert Indicators
- ✔ Precedent Followed – The Court followed well-established procedural law regarding infructuous petitions.