The Uttarakhand High Court reaffirmed that once a final report has been filed in a criminal matter, a writ petition challenging the pending investigation or process may be rendered infructuous. This order clarifies that such dismissals do not involve adjudication on merits and thus do not affect existing precedents in criminal procedure. Practitioners should note the strictly procedural nature and limited precedential value of such orders.
Summary
| Category | Data |
|---|---|
| Case Name | WPCRL/1031/2025 of SURENDRA DEV ARYA Vs STATE OF UTTARAKHAND |
| CNR | UKHC010142012025 |
| Date of Registration | 09-09-2025 |
| 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 | Procedural, no precedential value |
| Type of Law | Criminal Procedure |
| Ratio Decidendi |
The petition was dismissed as infructuous since, according to the State Counsel, the final report had already been filed in the matter. The Court did not adjudicate on the merits of the petition, observing that no further cause of action survived. The order reaffirms that procedural developments can render writ petitions infructuous where the underlying basis for relief ceases to exist. |
| Facts as Summarised by the Court |
The State Counsel informed the Court that a final report has been filed in the criminal case. In light of this, the writ petition was declared infructuous and dismissed without entering into the merits. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | No binding effect beyond the specific facts; limited to the parties. |
| Persuasive For | Demonstrates procedural approach, but not a source of legal principle. |
| Follows | Adopts standard practice when final report is filed during pendency of writ petition. |
What’s New / What Lawyers Should Note
- Clarifies that a criminal writ petition challenging investigation/proceedings becomes infructuous upon filing of the final report.
- Dismissal as infructuous does not decide substantive legal questions and sets no precedent.
- Practitioners should check the stage of investigation before approaching the writ court, as procedural developments may extinguish the cause of action.
Summary of Legal Reasoning
- The Court noted the submission of the State Counsel that the final report has been filed in the matter.
- On that basis, it held that the writ petition no longer survived for consideration and dismissed it as infructuous.
- There was no examination of merits or adjudication on legal issues, strictly adhering to the procedural consequence due to the changed circumstances.
- No reliance upon previous judgments or detailed statutory interpretation was required.
Arguments by the Parties
Petitioner
No separate submissions recorded in the order.
Respondent (State)
State Counsel submitted that the final report has been filed in the criminal matter.
Private Respondent
No separate submissions recorded in the order.
Factual Background
- A criminal writ petition was filed and listed for hearing before the Uttarakhand High Court.
- During the course of proceedings, the State Counsel apprised the Court that a final report had been filed in the underlying criminal case.
- The matter, thus, became infructuous and the petition was dismissed on that basis.
Statutory Analysis
- No statutory provisions were discussed or interpreted in the judgment.
- No analysis of criminal or constitutional law was undertaken, as the dismissal was purely on procedural grounds.
Dissenting / Concurring Opinion Summary
There are no dissenting or concurring opinions; the judgment is singular and unanimous.
Procedural Innovations
- The judgment reiterates the standard practice of dismissing writ petitions as infructuous when the final report is filed.
- No new procedural precedent, direction, or guideline was set.
Alert Indicators
- ✔ Precedent Followed – The order aligns with existing procedural practice in criminal writs becoming infructuous after filing of the final report.