The court reaffirmed that writ petitions become infructuous and liable for dismissal when the relief sought is rendered impossible due to supervening events—such as petitioners failing to qualify relevant entrance examinations. This judgment upholds existing precedent on mootness and finality, and acts as binding authority within Uttarakhand, with persuasive value elsewhere, particularly in educational admission litigation.
Summary
| Category | Data |
|---|---|
| Case Name | WPMS/2657/2024 of SMT RANJANA CHAUHAN Vs STATE OF UTTARAKHAND |
| CNR | UKHC010155012024 |
| Date of Registration | 27-09-2024 |
| Decision Date | 15-10-2025 |
| Disposal Nature | DISMISSED AS INFRUCTUOUS |
| Judgment Author | HON’BLE MR. JUSTICE MANOJ KUMAR TIWARI |
| Court | High Court of Uttarakhand |
| Precedent Value | Binding within Uttarakhand High Court jurisdiction |
| Type of Law | Procedural Law (Writ Petitions, Mootness) |
| Questions of Law | Whether writ petitions become infructuous and should be dismissed if the relief sought has been rendered impossible due to subsequent events, such as failure to qualify entrance examinations. |
| Ratio Decidendi |
The High Court held that when the foundation for a writ petition is negated by later developments—here, the petitioners’ failure to qualify in the entrance examination—the cause of action ceases to exist and the petition is rendered infructuous. The court endorsed dismissal in such cases, as the claims sought by the petitioners no longer survive. This reinforces the principle that courts do not decide academic or hypothetical questions and will only adjudicate live controversies. Interim relief, if any, also lapses upon dismissal. |
| Facts as Summarised by the Court |
Petitioners challenged issues related to admission in D.El.Ed. courses, but subsequently failed to qualify in the required entrance examination. Counsel for all petitioners acknowledged the petitions had been rendered infructuous, and the State counsel confirmed no surviving relief. The court thus dismissed all petitions as infructuous and vacated interim orders. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts in Uttarakhand |
| Persuasive For | High Courts of other states, especially in educational admission litigations |
| Follows | Established precedent on dismissal of moot/infructuous writ petitions |
What’s New / What Lawyers Should Note
- Reinforces that writ petitions are automatically liable for dismissal as infructuous if the relief prayed cannot be granted due to subsequent events, such as failure in requisite qualifying examinations.
- Affirms that courts will not continue to exercise writ jurisdiction over academic or hypothetical controversies once the underlying dispute is resolved by fact.
- Serves as a practical guide for litigants and practitioners in education-related writ matters regarding the consequence of failure in eligibility examinations.
Summary of Legal Reasoning
- The High Court took note of the explicit submissions from petitioners’ counsel that the basis for their writ challenges (i.e., participation in the D.El.Ed. admission process) was negated by petitioners’ inability to qualify in the entrance examination.
- The State’s counsel confirmed there was no surviving claim in the other petitions.
- The court concluded there was no live controversy or cause of action remaining, rendering the writ petitions infructuous.
- Pursuant to this, the court dismissed all connected petitions as infructuous and vacated any interim orders.
- The reasoning is anchored in the well-established judicial principle that courts will not proceed with petitions where no effective relief is possible due to changes in circumstances.
Arguments by the Parties
Petitioners
- Counsel for petitioners in WPMS/2637/2024, WPMS/2649/2024, and WPMS/2651/2024 explicitly submitted that the petitions had become infructuous as the petitioners failed to qualify the entrance examination for D.El.Ed. admission.
Respondent (State)
- State counsel submitted that the relief claimed in the other writ petitions no longer survives and supported dismissal as infructuous.
Factual Background
The petitioners filed writ petitions challenging aspects related to admission in the D.El.Ed. (Diploma in Elementary Education) course. During the pendency of the petitions, the petitioners took the prescribed entrance examination but failed to qualify. Petitioners’ counsel admitted before the High Court that the original relief sought in the petitions had become impossible to grant. The State concurred, leading the court to dismiss all petitions as infructuous.
Statutory Analysis
The judgment concerned the exercise of writ jurisdiction by the High Court, with particular emphasis on the principle that courts should only adjudicate live controversies. Reference was made to the futility of continuing writ proceedings where supervening events—such as not qualifying in an entrance examination—make it impossible for courts to grant any effective relief. No specific statutory provision was expansively interpreted or “read down” in the judgment.
Dissenting / Concurring Opinion Summary
No dissenting or concurring opinions are recorded in this judgment.
Procedural Innovations
No new procedural innovations or guidelines were set by the court in this judgment.
Alert Indicators
- ✔ Precedent Followed – The decision affirms established law on dismissal of writ petitions rendered infructuous due to subsequent factual developments.