Does a Statement by Counsel on Infructuous Writ Automatically Lead to Dismissal as Infructuous?

The court reaffirmed that when a petitioner’s counsel states that the writ petition has become infructuous, the writ petition can be summarily dismissed as infructuous—without entering the merits. This order upholds established procedural norms and functions as binding precedent within the High Court of Uttarakhand on administrative disposal of infructuous matters.

 

Summary

Category Data
Case Name WPSS/1115/2023 of MUKESH SHARMA Vs STATE OF UTTARAKHAND
CNR UKHC010105432023
Date of Registration 05-07-2023
Decision Date 15-10-2025
Disposal Nature DISMISSED AS INFRUCTUOUS
Judgment Author HON’BLE MR. JUSTICE MANOJ KUMAR TIWARI
Court High Court of Uttarakhand
Precedent Value Binding (within Uttarakhand High Court for administrative disposal of infructuous writs)
Type of Law Procedural/Administrative—Writ Jurisdiction
Ratio Decidendi

The court held that, upon a statement made by the petitioner’s counsel that the writ petition has become infructuous, it may be dismissed as infructuous accordingly.

The order did not examine merits or substantive questions of law, but was premised entirely on the counsel’s representation.

Facts as Summarised by the Court

Petitioner’s counsel stated that the writ petition has become infructuous.

Based on this statement, the petition was dismissed as infructuous.

Practical Impact

Category Impact
Binding On All subordinate courts and benches of the High Court of Uttarakhand for administrative dismissal of infructuous writs
Persuasive For Other High Courts when addressing administrative/pragmatic dismissals of infructuous petitions

What’s New / What Lawyers Should Note

  • Dismissal as infructuous can be summarily ordered on counsel’s statement, without further inquiry.
  • Lawyers should ensure the client’s intention before making such a statement, as it leads to immediate dismissal without examination of merits.
  • This practice maintains docket efficiency and upholds procedural economy in writ jurisdiction.

Summary of Legal Reasoning

  • The court recorded the categorical statement made by the petitioner’s counsel—that the writ petition had become infructuous.
  • Relying solely on this unambiguous statement, the court dismissed the writ petition as infructuous.
  • There was no discussion on the merits or any reasoned judicial determination—procedural efficiency and judicial time were prioritized.

Arguments by the Parties

Petitioner:

  • Counsel stated the writ petition had become infructuous.

Respondent (State):

  • No submissions recorded in the judgment.

Factual Background

  • The writ petition WPSS 1115/2023 was filed and listed before the High Court of Uttarakhand.
  • On the date of hearing, the petitioner’s counsel unambiguously stated the petition had become infructuous.
  • The petition was then dismissed as infructuous by the court on that basis, without entering merits.

Statutory Analysis

  • No statutory sections were discussed or interpreted in the order.
  • The procedural context was writ jurisdiction of the High Court.

Dissenting / Concurring Opinion Summary

No dissenting or concurring opinions were delivered; single judge bench.

Procedural Innovations

No new procedural innovations introduced; established practice followed.

Alert Indicators

  • ✔ Precedent Followed – Established procedural approach for dismissing infructuous petitions was reaffirmed.

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