Does the Court Have a Duty to Decide Writ Petitions When Relief Has Become Infructuous?

The High Court confirmed that writ petitions seeking reliefs which have become infructuous may be dismissed as such without adjudicating the merits. This order follows settled precedent, reinforcing consistent judicial practice, and will serve as binding authority for similar future situations.

 

Summary

Category Data
Case Name WP/23414/2020 of BEELA PARVATHI Vs THE STATE OF AP CNR APHC010352272020
Date of Registration 08-12-2020
Decision Date 02-09-2025
Disposal Nature DISMISSED AS INFRUCTUOUS
Judgment Author Dr. Justice Venkata Jyothirmai Pratapa
Court High Court of Andhra Pradesh
Precedent Value Binding precedent for identical procedural circumstances
Type of Law Constitutional law – Article 226, writ jurisdiction
Ratio Decidendi
  • The writ petition was dismissed as infructuous since the relief sought by the petitioner was no longer required.
  • The Court specifically recorded the submission of the petitioner’s counsel that the petition had become infructuous.
  • No order was passed on merits.
  • This practice affirms that courts may dispose of writ proceedings as infructuous when the relief becomes unnecessary, without pronouncing on the substantive legal issues.
Facts as Summarised by the Court
  • The petitioner sought a writ of mandamus to direct the police to provide protection for harvesting a paddy crop.
  • The issue became infructuous before adjudication, as submitted by the petitioner’s counsel.

Practical Impact

Category Impact
Binding On All subordinate courts within the jurisdiction of Andhra Pradesh High Court
Persuasive For Other High Courts and similar writ proceedings

What’s New / What Lawyers Should Note

  • The Court emphasized that writ petitions can be dismissed as infructuous when the relief sought is no longer necessary.
  • No findings are given on merits when a petition is dismissed as infructuous.
  • Counsel submissions on infructuousness, when accepted, may conclude proceedings without further inquiry.

Summary of Legal Reasoning

  • The Court, upon being informed by petitioner’s counsel that the relief sought had become infructuous, recorded this submission.
  • The writ petition was dismissed as infructuous and no order on costs or merits was passed.
  • There was no examination of the substantive legal claims in the petition.
  • This demonstrates that judicial resources need not be expended on matters where the sought relief is no longer required.

Arguments by the Parties

Petitioner

  • Through counsel, submitted that the relief sought had become infructuous and requested for disposal on that ground.

Respondents

  • Learned Assistant Government Pleader for Home was present.

Factual Background

The petitioner filed a writ petition under Article 226 seeking a mandamus to direct the police authorities to provide protection for harvesting a paddy crop on specific land in West Godavari District, alleging refusal of police protection due to ongoing civil disputes. During the hearing, petitioner’s counsel informed the Court that the relief sought had become infructuous. The Court, accordingly, disposed of the writ petition as infructuous.

Statutory Analysis

  • The writ petition was filed under Article 226 of the Constitution of India seeking judicial intervention by way of mandamus.
  • No substantive interpretation of statutes was undertaken as the matter was disposed of on procedural grounds (infructuousness).

Dissenting / Concurring Opinion Summary

No dissenting or concurring opinions were delivered.

Procedural Innovations

No new procedural innovations or guidelines were established in the judgment.

Alert Indicators

  • ✔ Precedent Followed – The decision affirms the settled practice regarding infructuous relief in writ proceedings.

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