Can a Writ Petition Seeking Further Relaxation of Cut-off Date and Upper Age Limit Survive When the Government Already Grants the Requested Relief?

Where a writ petition challenges recruitment criteria, the petition becomes infructuous & disposed of when the State extends sought relaxation, affirming procedural precedent.

 

Summary

Category Data
Case Name WPC/4681/2025 of SUDHAKAR JHA Vs THE STATE OF JHARKHAND
CNR JHHC010237422025
Date of Registration 25-08-2025
Decision Date 02-09-2025
Disposal Nature Infractous
Judgment Author Sri Ananda Sen, J.
Court High Court of Jharkhand
Bench Single Judge Bench
Precedent Value Binding within the territorial jurisdiction of Jharkhand High Court on handling infructuous writs
Type of Law Public Service / Service Law
Questions of Law Whether a writ petition concerning challenge to recruitment criteria survives after the relief sought (relaxation of cut-off date and upper age limit) is granted by the State.
Ratio Decidendi As the State extended the cut-off date and upper age limit as demanded by the petitioners, there remained no dispute to adjudicate. Consequently, the writ petition became infructuous and was disposed of accordingly. The Court affirmed that when the relief sought by the petitioner is already granted by subsequent government action, there is no necessity for judicial intervention.
Facts as Summarised by the Court Petitioners approached the Court seeking relaxation of the cut-off date and upper age limit for a public recruitment process. The government conceded to these demands, extending the benefits to all candidates including the petitioners. The Court, upon being informed, disposed of the petition as infructuous.

Practical Impact

Category Impact
Binding On All subordinate courts in Jharkhand
Persuasive For Other High Courts considering disposal of infructuous public service matters
Follows Established procedure that courts will not entertain issues where the relief sought is already granted

What’s New / What Lawyers Should Note

  • Restates that courts will promptly dispose of writ petitions as infructuous when the government or public authority extends the relief sought.
  • Confirms that no further adjudication is required when the factual or legal controversy is rendered moot by subsequent events.
  • Useful for respondents to argue early disposal when policy changes or notifications address the petitioner’s grievance during pendency.

Summary of Legal Reasoning

  • The Court recorded the petitioners’ submission that the government had already relaxed the cut-off date and upper age limit for all candidates as of 01.08.2018, extending the same benefit to the petitioners.
  • Observing that the basis of the writ petition no longer existed, the Court found no live issue for adjudication.
  • On this basis, the writ petition was held to be infructuous and disposed of accordingly, affirming that courts do not decide academic or infructuous matters.

Arguments by the Parties

Petitioner

  • Sought relaxation of cut-off date and upper age limit in a government recruitment process.
  • Submitted that, following the petition, relaxation was extended to all candidates (including himself).
  • Confirmed that he had accordingly submitted his form under the relaxed criteria.

Respondent (State)

  • No specific argument recorded; State’s relaxation of criteria was noted as the reason for disposal.

JPSC (Jharkhand Public Service Commission)

  • No specific argument recorded in the judgment.

Factual Background

The petitioners sought judicial redress for relaxation of the cut-off date and upper age limit in a public service recruitment process conducted by Jharkhand Public Service Commission. During the pendency of the case, the government relaxed the criteria as of 01.08.2018, extending the benefit to all candidates, including the petitioners. Consequently, the petitioners were able to apply as per their original demand, rendering the dispute non-existent.

Statutory Analysis

The judgment does not discuss or interpret any statutory provisions, as the petition was disposed of for infructuousness in light of subsequent government action fulfilling the prayer sought.

Procedural Innovations

No new procedural precedents or guidelines are set; the Court followed the established method for disposing of infructuous petitions.

Alert Indicators

  • Precedent Followed – Reaffirms the established principle that courts will not adjudicate infructuous or academic controversies.

Citations

  • Neutral citation: 2025:JHHC:26662

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