Where the main grievance underlying a writ petition is redressed by payment of dues during the pendency of the petition, such petitions are liable to be disposed of as infructuous without going into merits. Affirms the standard approach followed by the Punjab & Haryana High Court; binding precedent for government dues and service law matters.
Summary
| Category | Data |
|---|---|
| Case Name | CWP/19475/2024 of USHA JAIN AND ANR Vs UTTAR HARYANA BIJLI VITRAN NIGAM AND ORS |
| CNR | PHHC011039692024 |
| Date of Registration | 09-08-2024 |
| Decision Date | 10-09-2025 |
| Disposal Nature | DISPOSED OF |
| Judgment Author | MR. JUSTICE HARPREET SINGH BRAR |
| Court | High Court of Punjab and Haryana |
| Precedent Value | Binding authority in Punjab & Haryana on post-relief disposals |
| Type of Law | Service law / Writ under Articles 226/227 Constitution of India |
| Questions of Law | Is a writ petition seeking interest on delayed gratuity maintainable once the main relief (payment) is rendered during pendency? |
| Ratio Decidendi |
If the payment that forms the basis of a writ petition is made to the petitioner(s) during the pendency of the petition, and the relief sought stands substantially redressed, the writ petition is liable to be disposed of as infructuous. There is no requirement for the Court to adjudicate on the merits of ancillary claims, such as interest, once the substantive grievance is resolved. A petition ceases to survive if, before adjudication, the respondent acts to satisfy the main prayer of the petitioner(s). |
| Facts as Summarised by the Court |
A writ petition was filed seeking mandamus for interest on delayed gratuity payment. During pendency, the respondents made the payment. Counsel for petitioners stated that the main grievance was redressed and due payment already made. The Court therefore disposed of the petition as infructuous. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts and authorities within the jurisdiction of Punjab & Haryana |
| Persuasive For | Other High Courts in similar factual and procedural contexts |
What’s New / What Lawyers Should Note
- Clarifies that a writ petition seeking interest on delayed payment becomes infructuous if full payment is received prior to adjudication.
- Lawyers should consider informing the court promptly if the relief sought has already been received by the client, as the petition will be disposed of without detailed adjudication.
- Practical point: Subsequent claims for interest, if not explicitly reserved, may not be entertained once the writ is declared infructuous due to grant of principal relief.
Summary of Legal Reasoning
- The petition was for a writ of mandamus directing the respondent to grant interest on delayed gratuity payment.
- During the pendency of the matter, the petitioners received payment that addressed their main grievance.
- Counsel for the petitioners declared the grievance substantially redressed and payment made.
- The Court, noting that the relief sought was no longer required, disposed of the petition as infructuous, in accordance with established practice where a cause of action ceases to exist prior to adjudication.
Arguments by the Parties
Petitioner
- Sought mandamus for interest @ 18% per annum on delayed gratuity payment.
- Upon payment of the due amount by respondent, counsel submitted that grievance stood substantially redressed and due payment was already received.
Respondent
- None appeared as per record at the time of decision.
Factual Background
The petitioners filed a writ petition under Articles 226/227 of the Constitution seeking a writ of mandamus for payment of interest on delayed gratuity amounting to Rs. 2,17,848, which was sanctioned by the respondent authority. The claim was for interest for the period from 03.12.2011 to 22.12.2023. Before the case could be finally adjudicated, the respondents paid the due amount to the petitioners, and counsel for the petitioners informed the Court that the grievance had been addressed.
Statutory Analysis
- Articles 226/227 of the Constitution of India were invoked as the basis for seeking a writ of mandamus.
- No interpretation of statutory provisions or expansive reading was undertaken, as the matter was rendered infructuous before merits could be addressed.
Alert Indicators
- ✔ Precedent Followed – The disposal of infructuous writ petitions after grant of main relief is in accordance with established precedent.