Does the Filing of a Final Report Render a Criminal Writ Petition Infructuous Under Uttarakhand High Court Practice?

A writ petition filed becomes infructuous upon the filing of the final report by the investigating agency; the High Court summarily dismissed such a petition, affirming existing practice. This order aligns with standing procedure and serves mainly as a procedural reference for similar future cases in Uttarakhand.

 

Summary

Category Data
Case Name WPCRL/1740/2021 of AMIT SAINI Vs STATE OF UTTARAKHAND
CNR UKHC010115082021
Date of Registration 18-09-2021
Decision Date 29-10-2025
Disposal Nature DISMISSED AS INFRUCTUOUS
Judgment Author HON’BLE MR. JUSTICE ASHISH NAITHANI
Court High Court of Uttarakhand
Precedent Value Limited; procedural dismissal as infructuous
Questions of Law Whether the writ petition survives after a final report is filed by the investigating agency.
Ratio Decidendi

The court concluded that, since the final report has already been filed by the investigating agency, the criminal writ petition no longer survives and stands dismissed as infructuous.

The dismissal was based solely on this procedural stage, with no adjudication on merits. This order affirms prevailing practice regarding maintainability of writ petitions post-filing of final reports. There was no further discussion on underlying facts or legal controversy as the matter became academic.

Facts as Summarised by the Court The learned State Counsel informed the court that the final report had already been filed. On this basis, the court found there was nothing left to adjudicate and dismissed the writ petition as infructuous.

Practical Impact

Category Impact
Binding On Subordinate courts in Uttarakhand in similar procedural circumstances
Persuasive For Other High Courts — only on the narrow point of procedural infructuousness
Follows Affirms existing High Court practice for infructuous writs

What’s New / What Lawyers Should Note

  • Confirms that, once a final report is filed during the pendency of a criminal writ petition, such petition may be dismissed as infructuous.
  • Lawyers should be vigilant regarding the current procedural status of investigation and final reports before pursuing relief via criminal writ petitions.

Summary of Legal Reasoning

  • The court relied upon the statement by learned State Counsel that the final report had already been filed.
  • Upon this submission, the court summarily determined there was no surviving cause of action.
  • The court therefore exercised its discretion to dismiss the petition as infructuous, without entering into the merits.
  • No further legal or statutory interpretation was conducted as the petition was disposed on limited procedural grounds.

Arguments by the Parties

Petitioner

  • No specific arguments recorded in order; representation was through counsel.

Respondent (State)

  • Submitted that a final report had already been filed in the case.

Private Respondent

  • Representation through counsel noted; no further submissions recorded.

Factual Background

The criminal writ petition was pending before the Uttarakhand High Court. During course of proceedings, the learned State Counsel informed the court that the investigating agency had already filed its final report. In light of this development, the court found no subsisting controversy for adjudication and ordered dismissal on the ground of infructuousness.

Statutory Analysis

No statutory provision was expressly interpreted or analyzed in the judgment. The dismissal was based on procedural development rather than statutory construction.

Dissenting / Concurring Opinion Summary

No dissenting or concurring opinions are recorded in this judgment; the order is authored solely by the single presiding Judge.

Procedural Innovations

No new procedural innovations or guidelines were issued in this order.

Alert Indicators

  • ✔ Precedent Followed – The court followed established procedural practice concerning infructuousness of matters once final reports are filed.

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