The Court held that writ petitions which become infructuous due to supervening circumstances—such as petitioners no longer having locus because of failing an entrance examination—are to be dismissed as infructuous; such dismissal carries no precedential effect on the underlying questions of law or facts. The judgment affirms settled principles regarding the procedural fate of infructuous petitions, and provides clarity for educational admission and similar regulatory proceedings.
Summary
| Case Name | WPMS/2637/2024 of BHARTI DHINGRA Vs STATE OF UTTARAKHAND CNR UKHC010154342024 |
|---|---|
| Date of Registration | 26-09-2024 |
| Decision Date | 15-10-2025 |
| Disposal Nature | DISMISSED AS INFRUCTUOUS |
| Judgment Author | HON’BLE MR. JUSTICE MANOJ KUMAR TIWARI |
| Court | High Court of Uttarakhand |
| Bench | Single Judge Bench |
| Precedent Value | No precedential value on substantive law; only procedural disposition |
| Type of Law | Procedural law – Writ jurisdiction |
| Ratio Decidendi |
The Court observed that, as the petitioners failed to qualify in the entrance examination for D.El.Ed. course, the writ petitions had become infructuous. Similar statements were made by other petitioners and the State, noting that none of the pleaded reliefs survived for adjudication. Consequently, the petitions were dismissed as infructuous without examination of the merits. |
| Facts as Summarised by the Court |
Petitioners in various writ petitions sought relief regarding admission to the D.El.Ed. course. During proceedings, it was submitted by counsel for some petitioners that, since they had not qualified in the entrance examination, their petitions no longer survived. The State submitted that there was no surviving cause in the other petitions as well. |
Practical Impact
| Binding On | Not binding as to substantive law; only confirms dismissal as infructuous in similar procedural circumstances. |
|---|---|
| Persuasive For | None specified; not a precedent on the merits. |
What’s New / What Lawyers Should Note
- Dismissal of writ petitions as infructuous due to supervening events (such as failure to qualify in an examination) does not involve any determination of legal rights or the underlying issues.
- Such a dismissal is purely procedural and does not have precedential value for future cases on similar substantive questions.
- Lawyers should ensure to check for continued locus and survival of cause during pendency of writ proceedings.
- Interim orders automatically stand vacated when the main petition is dismissed as infructuous.
Summary of Legal Reasoning
- The learned counsel for certain petitioners submitted on record that, as the petitioners failed to qualify in the entrance examination for admission to the D.El.Ed. course, the necessity of adjudication no longer existed.
- The State Counsel similarly submitted that in other connected writ petitions, the relief sought by the petitioners no longer survived.
- Based on these submissions and the absence of a surviving cause of action, the Court dismissed all the writ petitions as infructuous.
- The Court specifically noted that any interim order passed also stands vacated by virtue of the dismissal.
Arguments by the Parties
Petitioner
- Learned counsel for the petitioners submitted that the writ petitions had become infructuous since the petitioners could not qualify in the relevant entrance examination.
Respondent/State
- The learned State Counsel submitted that the relief claimed in the other connected writ petitions also did not survive anymore.
Factual Background
- The petitioners had initiated writ proceedings seeking relief pertaining to admission to the D.El.Ed. course.
- During the pendency of the petitions, it emerged that certain petitioners did not qualify in the relevant entrance examination conducted for admission.
- In light of this factual development, it was submitted that the petitions had become infructuous.
- The State concurred that the relief claimed in the remaining petitions also no longer subsisted.
Statutory Analysis
The judgment does not involve substantive interpretation or analysis of statutory provisions, as the petitions were dismissed without adjudication on merits due to infructuousness.
Procedural Innovations
- The judgment followed established procedure by dismissing writ petitions as infructuous where the cause of action ceased to exist during pendency.
- Explicit direction that any interim order granted during the pendency automatically stands vacated upon disposal.
Alert Indicators
- ✔ Precedent Followed – The Court followed settled procedure that writ petitions become infructuous when relief claimed no longer survives due to subsequent events.