A writ petition seeking expeditious disposal becomes infructuous if, during its pendency, the requested proceeding is already concluded by the authority. This judgment affirms the established procedure and is binding within Uttarakhand, providing persuasive value elsewhere, particularly in administrative and revenue litigation contexts.
Summary
| Category | Data |
|---|---|
| Case Name | WPMS/2371/2025 of MS RAM ASSOCIATES VIKAS COLONY Vs STATE OF UTTARAKHAND |
| CNR | UKHC010123102025 |
| Date of Registration | 07-08-2025 |
| Decision Date | 10-09-2025 |
| Disposal Nature | DISMISSED AS INFRUCTUOUS |
| Judgment Author | HON’BLE MR. JUSTICE PANKAJ PUROHIT |
| Court | High Court of Uttarakhand |
| Precedent Value | Binding on Uttarakhand subordinate courts; persuasive elsewhere |
| Type of Law | Administrative / Writ Jurisdiction / Revenue Law |
| Questions of Law | Whether a writ petition seeking expeditious disposal is rendered infructuous if the authority disposes of the underlying proceeding during pendency of the writ? |
| Ratio Decidendi |
The High Court held that if, during the pendency of a writ petition seeking a direction for early disposal of proceedings before a statutory authority, the authority concludes the matter, then the writ petition becomes infructuous. The court took on record written instructions from the State Counsel demonstrating that the proceeding in question had already been finalized. No further orders were deemed necessary as the core grievance had ceased to exist. This approach is in line with procedural norms in writ jurisdiction, prioritizing judicial economy and efficiency. |
| Facts as Summarised by the Court |
The petitioner sought a writ directing the Tehsildar, District Haridwar, to expeditiously decide case No.769/2024-25 under Section 34/35 of the LR Act. The State Counsel produced written instructions to the effect that the Tehsildar had already decided the case on 12.12.2024. Consequently, the writ petition’s subject matter no longer survived. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts in Uttarakhand with reference to administrative/writ matters where the grievance ceases to exist due to action taken during proceedings. |
| Persuasive For | Other High Courts and revenue tribunals dealing with similar writs concerning expeditious disposal requests. |
What’s New / What Lawyers Should Note
- Confirmation that once the authority disposes of the underlying matter, writ petitions seeking directions for such disposal are to be dismissed as infructuous.
- Written instructions from the State Counsel regarding factual developments can be taken on record and relied upon to adjudicate writ petitions.
- No further directions will be given if the core grievance no longer subsists at the time of hearing.
- Saves judicial time and parties’ resources by not issuing redundant orders on concluded issues.
Summary of Legal Reasoning
- The petitioner requested a direction for expeditious disposal of a pending case before the Tehsildar under the LR Act.
- The court received and accepted written instructions from the State Counsel stating that the Tehsildar had already decided the case.
- On this basis, the court found the writ petition to be infructuous, as the relief sought had already been rendered pointless by subsequent events.
- The court accordingly dismissed the writ petition as infructuous, without issuing further directions or orders.
Arguments by the Parties
Petitioner
- Sought a writ to direct the Tehsildar, District Haridwar, to decide case No.769/2024-25 under Section 34/35 of the LR Act expeditiously.
Respondent (State)
- Submitted written instructions informing the court that the Tehsildar had already disposed of the case on 12.12.2024.
Factual Background
The petitioner approached the High Court seeking a direction to the Tehsildar, District Haridwar, to decide case No.769/2024-25 under Section 34/35 of the LR Act without delay. During the proceedings, the State informed the court through written instructions that the case had already been finalized by the Tehsildar on 12.12.2024. As a result, the original grievance of the petitioner no longer survived, and the petition was dismissed as infructuous.
Statutory Analysis
- The judgment references Section 34/35 of the LR Act (Land Revenue Act), under which the pending case was to be decided by the Tehsildar.
- No expansive or narrow interpretation of statutory text is undertaken, as the relief became academic due to subsequent factual developments.
Alert Indicators
- ✔ Precedent Followed – The judgment affirms the established practice of disposing writs as infructuous when relief sought is no longer required.