A writ petition seeking correction of a seniority list becomes infructuous if, during its pendency, the administrative action already accords the sought relief—here, inclusion in the seniority list. The judgment upholds existing law and reiterates the approach to such circumstances, serving as precedent for state service seniority matters where relief is granted by the government prior to judicial determination.
Summary
| Category | Data |
|---|---|
| Case Name | WP(C)/492/2025 of Soraisham Anita Chanu and 2 ors Vs State of Manipur and Anr |
| CNR | MNHC010017022025 |
| Date of Registration | 01-07-2025 |
| Decision Date | 29-10-2025 |
| Disposal Nature | Disposed Off |
| Judgment Author | Hon’ble Mr. Justice Ahanthem Bimol Singh |
| Court | High Court of Manipur |
| Bench | Single Judge |
| Precedent Value | Binding on subordinate courts in Manipur; persuasive for other High Courts. |
| Type of Law | Service Law (Seniority, Government Employment) |
| Questions of Law | Whether relief granted by the authorities during pendency of a writ petition renders it infructuous. |
| Ratio Decidendi |
The court held that where the administrative authorities have, during the pendency of a writ petition, granted the precise relief sought by the petitioners—in this case, inclusion of their names in the seniority list—the petition becomes infructuous. The court, upon recording statements by both parties confirming this, closed the writ petition without proceeding to adjudicate further. This approach reinforces the principle of judicial economy, avoiding unnecessary adjudication when controversy ceases to exist. |
| Facts as Summarised by the Court |
Petitioners sought a direction to include their names in the seniority list of Youth Officers/Supdt.(P)/Coaches in the Directorate of Youth Affairs & Sports, Manipur. During the writ petition’s pendency, the respondents included the petitioners’ names at serial numbers 24, 25, and 26 via notification dated 08.10.2025. Both parties confirmed the relief had been granted, thus necessitating closure of proceedings as infructuous. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts and authorities in Manipur. |
| Persuasive For | Other High Courts in India and relevant service law forums. |
What’s New / What Lawyers Should Note
- Reiterates that administrative satisfaction of a petitioner’s claim during proceedings makes the writ petition infructuous.
- Judicious closure of cases avoids unnecessary judicial pronouncement when the disputing issue no longer survives.
- Lawyers should monitor for administrative relief during litigation to seek closure on grounds of infructuousness, where appropriate.
- Court formally records and accepts such relief for the record, ensuring judicial finality.
Summary of Legal Reasoning
- The court noted the petitioner’s initial grievance: non-inclusion in the Combined Tentative Seniority List.
- During the writ petition’s pendency, petitioners’ names were included via official notification.
- Both sides submitted that the writ’s foundational grievance had been redressed.
- The court, recording these submissions and the production of the notification as exhibit “X”, found no surviving cause of action.
- The writ petition was thus closed as infructuous, following the settled principle that courts do not decide academic or moot questions where relief is already granted.
- The matter was disposed of without adjudication of the merits.
Arguments by the Parties
Petitioner
- Sought inclusion of their names in the Combined Tentative Seniority list by the Directorate of Youth Affairs & Sports, Manipur.
- Submitted that the notification dated 08.10.2025 granted the relief sought.
- Requested closure of the writ petition as infructuous.
Respondent
- Confirmed issuance of the notification including petitioners’ names.
- Did not object to closure of the petition as infructuous.
Factual Background
The petitioners filed a writ petition seeking inclusion of their names in the seniority list of Youth Officers/Supdt.(P)/Coaches under the Directorate of Youth Affairs & Sports, Government of Manipur. While the matter was pending, the authorities issued a notification on 08.10.2025, inserting petitioners’ names at serial numbers 24, 25, and 26. Consequently, the original grievance stood resolved during the course of litigation.
Statutory Analysis
- The judgment does not specifically set out or interpret statutory provisions, but applies the general principle that courts will not adjudicate writ petitions which have become infructuous because the relief sought has been granted administratively.
- The approach is consistent with judicial principles of avoiding academic or hypothetical adjudication.
Procedural Innovations
- The court formally marks the notification granting relief as an exhibit (“X”) for identification and record.
- The procedure ensures clear record-keeping for closure of matters as infructuous following administrative resolution.
Alert Indicators
- ✔ Precedent Followed – The judgment upholds settled law regarding disposal of infructuous petitions.