When Can a Writ Petition Be Dismissed as Infructuous Due to Supervening Events?

The court reaffirmed that if, during the pendency of a writ petition, the relief claimed is granted or the issue is resolved, the petition becomes infructuous and is liable to be dismissed. This ruling upholds established procedural law and constitutes binding precedent for subordinate courts handling writ petitions where the cause of action ceases to exist during proceedings.

 

Summary

Category Data
Case Name WPMS/2561/2025 of DEVI RAM Vs DISTRICT MAGISTRATE
CNR UKHC010134702025
Date of Registration 27-08-2025
Decision Date 01-09-2025
Disposal Nature DISMISSED AS WITHDRAWN (infructuous)
Judgment Author HON’BLE MR. JUSTICE MANOJ KUMAR TIWARI
Court High Court of Uttarakhand
Bench Single Bench
Precedent Value Binding on subordinate courts
Type of Law Procedural Law
Ratio Decidendi

The Court held that where, subsequent to the filing of a writ petition, the relief sought has already been granted—here, correction of the petitioner’s name in revenue records—the petition becomes infructuous.

As a result, the Court found no grounds to continue proceedings and dismissed the writ as no longer maintainable.

Practical Impact

Category Impact
Binding On All subordinate courts in Uttarakhand
Persuasive For Other High Courts

What’s New / What Lawyers Should Note

  • Confirms that writ petitions become infructuous if during pendency the sought relief is achieved.
  • Counsel should promptly inform courts of any supervening developments affecting relief.
  • Saves parties and courts time by preventing unnecessary adjudication of moot issues.

Summary of Legal Reasoning

  • The court noted the petitioner, through counsel, admitted that the relief sought (correction of name in revenue records) had already been granted post-filing.
  • Recognizing that the matter had been resolved, the Court reasoned that continuing the petition would serve no purpose.
  • The petition was accordingly dismissed as infructuous on the basis that judicial time should not be spent on academic or moot issues where no live controversy remains.

Arguments by the Parties

Petitioner:

  • Informed the Court that the petitioner’s name had been corrected in the revenue records after the writ’s filing.
  • Submitted that the relief originally claimed thus no longer survived.

Respondent:

  • No further argument recorded on merit, as the petitioner’s counsel stated the cause was resolved.

Factual Background

The petitioner filed a writ petition seeking correction of their name in the revenue records. During the pendency of the case, the name was duly corrected. Upon being apprised of this development, the petitioner’s counsel informed the Court that the relief no longer survived.

Statutory Analysis

The judgment did not undertake statutory interpretation but relied upon well-established procedural principles governing the maintainability of writ petitions and mootness.

Dissenting / Concurring Opinion Summary

None. Single-bench judgment.

Procedural Innovations

None indicated.

Alert Indicators

  • ✔ Precedent Followed – Court follows and applies existing procedural law regarding dismissal of infructuous petitions.

Citations

  • 2025:UHC:7731
  • WPMS/2561/2025
  • CNR: UKHC010134702025

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