Does Payment Fulfilling Petitioner’s Claim Render Pending Writ Petitions Infructuous? – Upholding Procedural Finality in Constitutional Writ Jurisdiction

When the subject of a writ petition—here, the claim for payment—is fulfilled during the pendency of proceedings, the Calcutta High Court affirms the established procedural approach to dispose of such petitions as infructuous. The decision reinforces existing precedent, providing binding guidance for subordinate courts within the jurisdiction in similar fact situations.

 

Summary

Category Data
Case Name WPA/8004/2025 of Mahadeb Das Vs State of West Bengal and Ors.
CNR WBCHCA0160912025
Date of Registration 05-04-2025
Decision Date 31-10-2025
Disposal Nature DISPOSED
Judgment Author HON’BLE JUSTICE AMRITA SINHA
Court Calcutta High Court
Precedent Value Binding within Calcutta High Court jurisdiction
Type of Law Constitutional Writ Jurisdiction
Ratio Decidendi

Where the relief sought in a writ petition—here, the payment due to the petitioner—has been satisfied during the pendency of proceedings, there remains no requirement to proceed further with the petition.

The writ petition is thereby disposed of as infructuous. Confirmation by counsel on behalf of both parties is considered sufficient to establish fulfillment of the claim.

Facts as Summarised by the Court

Both advocates, upon instruction, submitted that payment due to the petitioner has been made.

Consequently, the court found there was no further requirement to proceed with the petition and disposed of it.

Practical Impact

Category Impact
Binding On All subordinate courts within the territorial jurisdiction of Calcutta High Court.

What’s New / What Lawyers Should Note

  • Reinforces that once the petitioner’s relief has been fulfilled during pendency, writ petitions should be disposed of as infructuous.
  • Written submissions by advocates confirming satisfaction of claim are sufficient for disposal.
  • No elaborate reasoning or further orders are required where the grievance is resolved.

Summary of Legal Reasoning

  • The court recorded statements from learned advocates for both petitioner and State, made upon instruction, confirming that payment to the petitioner had been made.
  • Based on the fulfillment of the relief sought, the court held there was no requirement to proceed with the writ petition.
  • The petition was accordingly disposed of, observing procedural propriety in light of satisfaction of the petitioner’s claim.

Arguments by the Parties

Petitioner

  • Through advocate, confirmed upon instruction that payment had been made.

Respondent (State)

  • Through advocate, similarly submitted upon instruction that payment had been made to petitioner.

Factual Background

  • The petitioner filed a writ petition seeking payment from the State.
  • During the pendency of proceedings, payment was made to the petitioner.
  • At the hearing, both parties, via their advocates, confirmed to the court that the claim had been fulfilled.
  • The court, noting this development, found no reason to proceed with the writ petition.

Statutory Analysis

  • The order was passed in exercise of constitutional writ jurisdiction.
  • The court noted procedural sufficiency in disposing of a petition where the core relief was granted during pendency.

Alert Indicators

  • ✔ Precedent Followed – The judgment applies and confirms existing procedural law on disposal of infructuous petitions following fulfillment of relief.

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