Court’s Decision
In a judgment dated 6 June 2025, the Allahabad High Court (Lucknow Bench) disposed of a petition filed under Article 227 of the Constitution of India with a direction to the State Public Services Tribunal, Lucknow, to expedite the hearing and adjudication of Claim Petition No. 0003 of 2023. The Court directed that the petition be decided “expeditiously preferably within a period of eight months” from the date the certified copy of the order is served. The Court intervened in view of the prolonged pendency and noted that the delay in disposing of the service matter was causing harassment to the petitioner.
Facts
The petitioner approached the High Court under Article 227 of the Constitution of India seeking expeditious disposal of Claim Petition No. 0003 of 2023 filed before the State Public Services Tribunal, Lucknow. The original claim petition, which involved service-related grievances, had been filed in 2023 and remained pending before the Tribunal without any substantial progress or decision. As a result, the petitioner submitted that the continued pendency was causing undue hardship and harassment, and sought judicial intervention to ensure time-bound disposal of the claim.
The reliefs prayed for by the petitioner were as follows:
- A direction to the Tribunal (Respondent No. 1) to decide the pending Claim Petition No. 0003 of 2023 (Rajendra v. State of U.P. and Another) expeditiously within a stipulated time frame.
- Any other relief or direction deemed just and proper by the Court.
- Costs to be awarded in favour of the petitioner.
Issues
- Whether the High Court ought to intervene under Article 227 of the Constitution to ensure timely adjudication of a long-pending service matter.
- Whether delay in disposal of the claim petition before the Tribunal constitutes harassment sufficient to warrant supervisory intervention.
Petitioner’s Arguments
The petitioner contended that despite having filed the claim petition in 2023 before the State Public Services Tribunal, Lucknow, no decision had been rendered. The inordinate delay in the adjudication was causing severe hardship and procedural harassment. The petitioner argued that such delays not only defeat the object of justice but also frustrate the right to an effective legal remedy. It was, therefore, submitted that the High Court should direct the Tribunal to dispose of the claim within a reasonable and fixed time frame.
Respondent’s Arguments
The learned Standing Counsel appearing for the State submitted that he had no objection if the Court issued a direction for the time-bound disposal of the pending claim petition. This stand of the State indicated that even the respondent did not justify the delay and acknowledged the need for speedy resolution of service disputes.
Analysis of the Law
The Court relied on its inherent powers under Article 227 of the Constitution, which vests supervisory jurisdiction in the High Courts over all subordinate courts and tribunals within their territorial limits. The Article is primarily intended to keep the subordinate judiciary within the bounds of their authority and to ensure that justice is neither delayed nor denied.
Service matters, particularly those relating to employment disputes, often involve the question of livelihood and fundamental rights of individuals. Prolonged delay in their resolution can have a cascading effect on the rights and entitlements of the claimants. Recognizing this, constitutional courts have repeatedly emphasized the need for timely disposal of such cases.
By exercising its supervisory jurisdiction in the present matter, the Court has reaffirmed that delays in administrative justice must be curtailed and claimants must not be made to suffer unnecessarily due to procedural inertia.
Precedent Analysis
While the Court in this order did not cite specific precedents, its reasoning is supported by the following landmark decisions:
- Surya Dev Rai v. Ram Chander Rai, (2003) 6 SCC 675
– This case clarified the scope of the High Court’s jurisdiction under Article 227, holding that supervisory powers may be invoked to correct grave dereliction of duty or injustice. - K.K. Shrivastava v. Bhupendra Kumar Jain, (1977) 1 SCC 494
– In this case, the Supreme Court underscored the importance of expeditious disposal of service-related disputes. - Raj Kumar v. Union of India, (1975) 4 SCC 13
– Held that delayed consideration in service matters could result in irreparable damage to the employee’s rights.
The present order reflects these judicial principles and enforces them in the specific context of the pendency of a claim petition before a statutory tribunal.
Court’s Reasoning
The Court noted that the petitioner had filed Claim Petition No. 0003 of 2023 before the Tribunal, and despite the lapse of significant time, no progress had been made in adjudicating the dispute. Accepting the petitioner’s submission regarding harassment due to the prolonged pendency, and in view of the fact that the State did not object to the fixing of a time frame, the Court found it appropriate to intervene.
The Court observed:
“I find that the claim petition had been filed in the year 2023 and is pending before the learned Tribunal… This petition is disposed of with a direction to Respondent No. 1 to expedite the hearing… and decide it expeditiously preferably within a period of eight months.”
This clear and categorical directive was issued to balance the ends of justice with administrative efficiency.
Conclusion
The Allahabad High Court (Lucknow Bench) exercised its jurisdiction under Article 227 to ensure that a claim pending before the State Public Services Tribunal, Lucknow, was not left undecided for an unreasonable period. The Court concluded that the petitioner had established valid grounds for seeking timely adjudication, and thus, it directed the Tribunal to decide the claim within eight months from the date of service of the certified copy of the order.
Implications
The judgment reaffirms the High Court’s role in preventing delays in quasi-judicial and tribunal-based proceedings, especially in service jurisprudence. It also sets a precedent for litigants aggrieved by unreasonable delays to invoke Article 227 to seek remedial directions. The Court’s willingness to intervene even in the absence of adversarial contest from the State underscores its commitment to constitutional fairness, administrative efficiency, and access to timely justice.
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