The High Court reaffirmed that a writ petition seeking an administrative action (such as the allotment of a transformer) may be disposed of as infructuous if, by the hearing date, the relief sought is no longer relevant or sustainable. This clarifies that such dismissals do not address the merits, and do not create binding precedents—making them of limited utility for future cases concerning similar factual circumstances.
Summary
| Category | Data |
|---|---|
| Case Name | WP/19812/2014 of SRI LAXMI NARASIMHA CONSTRUCTIONS, W.G.DIST. Vs A.P.E.P.D.C.L., VISAKHAPATNAM, & 4 OTRS. |
| CNR | APHC010547082014 |
| Date of Registration | 15-07-2014 |
| Decision Date | 02-09-2025 |
| Disposal Nature | DISPOSED OF AS INFRUCTUOUS |
| Judgment Author | Justice Gannamaneni Ramakrishna Prasad |
| Court | High Court of Andhra Pradesh |
| Precedent Value | Not binding as to merits; clarifies treatment of infructuous petitions |
| Type of Law | Administrative Law / Writ Jurisdiction |
| Questions of Law | Whether the Court should continue to adjudicate a writ petition when the original relief sought has become irrelevant due to lapse of time or other developments. |
| Ratio Decidendi |
The Court held that where a writ petition seeks relief for an administrative action that is rendered irrelevant by subsequent events or lapse of time, such a petition is liable to be disposed of as infructuous. The dismissal does not address the merits of entitlement to relief but only recognizes that the relief sought has ceased to survive. The order closing the petition is not to be treated as a determination of rights or legal positions. The case demonstrates the importance of prompt action and regular follow-up in writ proceedings involving time-sensitive administrative relief. |
| Facts as Summarised by the Court | The petitioner filed a writ for allotment and installation of a transformer, alleging inaction on an application dated 14.05.2014. An interim direction was issued for disposal of the application. At final hearing, the relief had lost relevance, and the petition was closed as infructuous. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | Not binding on subordinate courts as to the substantive legal issue; clarifies procedural course for similar circumstances. |
| Persuasive For | May be cited for the proposition that infructuous writ petitions are not decided on merits. |
What’s New / What Lawyers Should Note
- Reaffirms that writ petitions seeking time-sensitive administrative relief may be dismissed as infructuous if the underlying issue does not survive till final hearing.
- Clarifies that such dismissals are not on merits and cannot be cited as precedent on the substantive legal issue.
- Underscores the importance of timely prosecution and regular follow-ups in writ litigation involving administrative orders.
- Lawyers should anticipate and address possible mootness or infructuousness before the matter is listed for final hearing.
Summary of Legal Reasoning
- The Court first recalled the interim order directing the respondent to decide the petitioner’s representation for allotment of a transformer within four weeks.
- Upon final hearing, the Court found that the prayer for administrative action (transformer allotment/installation) did not survive, as the factual circumstances had changed or the issue had been overtaken by events.
- The reasoning was that judicial time should not be spent on hypothetical or academic questions when the real dispute or relief sought is no longer live.
- Accordingly, the writ petition was disposed of as infructuous, with no determination on the merits and no orders as to costs.
Arguments by the Parties
Respondent
- Argues through standing counsel that the interim direction was complied with and/or the relief sought by the petitioner is no longer surviving. Supports disposal of writ petition as infructuous.
Factual Background
The petitioner filed a writ petition seeking the allotment and installation of an electrical transformer at its property, citing non-action on its 14.05.2014 application to the electricity distribution company. The High Court initially issued an interim order directing the respondent to decide the petitioner’s application expeditiously. By the time the petition was posted for final hearing, the relief sought was no longer relevant, leading the Court to dispose it as infructuous.
Statutory Analysis
The judgment pertains to the writ jurisdiction of the High Court for issuing directions to public authorities regarding administrative functions, but no specific statutory section is interpreted or analyzed in detail.
Dissenting / Concurring Opinion Summary
None; single-judge bench, no separate opinions recorded.
Procedural Innovations
None indicated; standard disposal of infructuous petition, following long-standing procedure.
Alert Indicators
- Precedent Followed – The judgment follows existing practice regarding infructuous writ petitions and does not create or break precedent.
Citations
No SCC, AIR, MANU, or neutral citations noted in the judgment. Decision is non-reportable as per available record.