The Calcutta High Court reaffirms that, in the absence of statutory obligation, the State is not bound to resolve internal or inter se disputes within the film and television industry through writ jurisdiction. The judgment upholds established precedent regarding the non-intervention of courts in disputed questions of fact and clarifies the limits of judicial review in such cases. This ruling will serve as binding authority within West Bengal for similar industry-based disputes seeking writ remedies.
Summary
| Category | Data |
|---|---|
| Case Name | WPA/7543/2025 of PROSENJIT MALLICK Vs STATE OF WEST BENGAL AND ORS. CNR WBCHCA0151242025 |
| Date of Registration | 01-04-2025 |
| Decision Date | 10-09-2025 |
| Disposal Nature | DISMISSED |
| Judgment Author | HON’BLE JUSTICE AMRITA SINHA |
| Court | Calcutta High Court |
| Bench | Constitutional Writ Jurisdiction, Appellate Side |
| Precedent Value | Binding within the jurisdiction of the Calcutta High Court |
| Type of Law | Constitutional/Administrative Law (Writ Jurisdiction under Article 226) |
| Questions of Law |
|
| Ratio Decidendi |
The Court held that the State has no legal obligation to resolve internal disputes among parties within the film and television industry where there is no statutory duty. The existence of disputed questions of fact renders writ jurisdiction inapplicable. Judicial review under Article 226 is limited when the controversy centers on private or internal industry matters and requires resolution of disputed facts. |
| Facts as Summarised by the Court |
The dispute concerned the film and television industry in West Bengal. All claims and facts raised by the petitioner were strongly contested by the respondents. The State indicated its unwillingness and lack of responsibility to mediate or resolve such inter se disputes. The matter was previously referred to the Principal Secretary, Information and Cultural Affairs Department, who proposed a committee, but respondents objected, and the State ultimately expressed its intention not to intervene. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts within West Bengal |
| Persuasive For | Other High Courts and potentially the Supreme Court in analogous fact situations |
What’s New / What Lawyers Should Note
- Reaffirms that writ jurisdiction is not the proper forum for resolving highly disputed factual matters, especially in the absence of statutory duty on part of the State.
- Clarifies that the State/government cannot be compelled to resolve inter se or internal disputes of a private or semi-private industry unless there is a clear statutory or constitutional obligation.
- Lawyers representing parties in the film and television industry (and analogous sectors) must seek remedies other than writ petitions in similar fact situations.
- Reinforces the judicial restraint principle with respect to non-justiciable industry disputes brought through Article 226 petitions.
Summary of Legal Reasoning
- The Court noted that the matter pertains to disputes within the film and television industry, for which no specific statutory duty is cast on the State to act as an arbitrator or mediator.
- The writ petition involved facts and allegations that were heavily disputed by the parties, making it unsuitable for adjudication under writ jurisdiction.
- The Principal Secretary’s suggestion for a committee was only an opinion, and the State explicitly denied any obligation to ensure the smooth functioning of the film and television industry in such contexts.
- The Court highlighted the principle that writ courts should refrain from intervening in matters involving complex factual determinations or inter se private disputes, especially where equally efficacious alternate remedies exist.
- The petition was dismissed, with liberty to the parties to pursue such remedies as are available under the law.
Arguments by the Parties
Petitioner:
- Sought judicial intervention to address issues faced in the functioning of the film and television industry.
Respondent (State):
- Submitted that the State is not obliged to resolve inter se disputes between private parties within the industry.
- Asserted a lack of statutory responsibility regarding the operational functioning of the industry.
Respondent Nos. 3, 4, 5:
- Raised serious objections to the proposal for a committee or State intervention.
- Disputed each and every fact, claim, and allegation advanced by the petitioner.
Factual Background
The case arose from problems faced by the petitioner in the film and television industry of West Bengal. The issue was referred to the Principal Secretary of the Information and Cultural Affairs Department, who conducted hearings and suggested forming a committee of eminent industry persons. This suggestion was opposed by the respondents, and the State government conveyed that it bore no obligation to resolve such inter-party disputes. The facts and allegations made by the petitioner were entirely disputed, leading to dismissal of the writ on the ground of disputed facts and absence of enforceable duty on the State.
Statutory Analysis
The judgment analyzed the scope of writ jurisdiction under Article 226 of the Constitution. The Court emphasized that judicial review in such writ petitions is limited, particularly when no statutory or constitutional obligation exists for the State to resolve internal industry matters, and where disputed facts render summary adjudication inappropriate.
Alert Indicators
- ✔ Precedent Followed – Existing law regarding limits of writ jurisdiction, especially in resolving disputed facts and internal, non-statutory industry disputes, has been reaffirmed.