The High Court of Uttarakhand reaffirms that if, during the pendency of a writ petition, the petitioner’s grievance is resolved, the petition is to be dismissed as infructuous rather than adjudicated on merits. This follows existing precedent and stands as binding authority for all subordinate courts and persuasive authority in other jurisdictions.
Summary
| Category | Data |
|---|---|
| Case Name | WPMB/902/2025 of MS PRAMOD KUMAR GOVT CONTRACTOR AND GENERAL ORDER SUPPLIER Vs STATE OF UTTARAKHAND |
| CNR | UKHC010167142025 |
| Date of Registration | 16-10-2025 |
| Decision Date | 28-10-2025 |
| Disposal Nature | DISPOSED |
| Judgment Author | HON’BLE MR. JUSTICE RAVINDRA MAITHANI, HON’BLE MR. JUSTICE ALOK MAHRA |
| Court | High Court of Uttarakhand |
| Bench | Division Bench: HON’BLE MR. JUSTICE RAVINDRA MAITHANI, HON’BLE MR. JUSTICE ALOK MAHRA |
| Precedent Value | Binding on all subordinate courts in Uttarakhand; persuasive elsewhere |
| Overrules / Affirms | Affirms existing legal position |
| Questions of Law | Whether a writ petition should be dismissed as infructuous when the grievance is redressed during pendency. |
| Ratio Decidendi | The Court held that when the grievance for which the writ petition was filed stands redressed during the pendency of the petition, the writ petition does not survive for adjudication and is to be dismissed as infructuous. In such cases, adjudication on merits is unnecessary as no live dispute remains for the court to decide. |
| Facts as Summarised by the Court | At the outset, the petitioner’s counsel admitted that the grievance had already been redressed, rendering the petition infructuous. Consequently, the Court dismissed the petition as infructuous without entering into the merits. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts in Uttarakhand |
| Persuasive For | Other High Courts, Supreme Court |
| Follows | The general principle that courts do not adjudicate infructuous matters; existing precedents |
What’s New / What Lawyers Should Note
- Reaffirms that writ petitions are liable to be dismissed as infructuous when the core grievance is resolved before the hearing/adjudication.
- No merits-based adjudication occurs in such cases; petitioners and respondents should consider this while pursuing or defending writs.
- Admission of redressal by the petitioner’s counsel is sufficient for court to dispose as infructuous.
Summary of Legal Reasoning
- The Bench noted at the outset of the hearing that the petitioner’s counsel made a statement that the grievance has been redressed.
- The Court recognized that with the redressal of the grievance, no live issue or dispute survives for adjudication.
- Consistent with established legal practice, when a petition becomes infructuous, the court dismisses it as such rather than entering into merits.
- The order thus records the dismissal of the writ petition for having become infructuous as a consequence of the admitted redressal of grievance.
Arguments by the Parties
Petitioner
- Grievance forming the basis of the writ petition has already been redressed.
- Prays for dismissal of the petition as having become infructuous.
Respondent (State and private parties)
No arguments recorded; court acted upon the petitioner’s submission.
Factual Background
The petitioner originally filed a writ petition in the High Court of Uttarakhand seeking redressal of a grievance. At the time of hearing, counsel for the petitioner informed the court that the grievance had already been addressed. As a result, the issue no longer subsisted and the matter was taken up only for passing necessary orders in view of this development.
Statutory Analysis
No particular statutory provision was discussed or interpreted in the order, as the matter was disposed of on the basis of redressal of grievance and resulting infructuousness.
Dissenting / Concurring Opinion Summary
No dissenting or separate concurring opinion was recorded; both judges concurred in dismissing the petition as infructuous.
Procedural Innovations
No new procedural innovations or guidelines were issued; the court followed the established procedure of disposing infructuous petitions based on submissions of counsel.
Alert Indicators
- ✔ Precedent Followed – The decision reaffirms established legal principle regarding dismissal of infructuous petitions.