Chhattisgarh High Court Dismisses Four Writ Petitions, Observes “No Purpose Served When Relief Is Moot,” as Issues Become Irrelevant Due to Changed Circumstances

Court’s Decision

The High Court of Chhattisgarh dismissed four writ petitions—WPC Nos. 2035, 2037, 2036, and 2074 of 2016—on grounds that the petitions had become infructuous. The court noted that the issues raised in the petitions no longer required adjudication, as acknowledged by either the petitioners or the respondents during proceedings.

Facts

The petitions involved various grievances against the State of Chhattisgarh, its Directorate of Technical Education, the University Grants Commission (UGC), and affiliated universities. The petitions sought to address administrative and regulatory actions impacting higher education institutions and students.

1. Petitioners in WPC Nos. 2035 and 2037:
   • Filed grievances relating to certain policies or decisions involving the UGC, the Directorate of Technical Education, and the State.
   • During the hearing, the counsel for the UGC submitted that the issues had become moot and required no further intervention.
2. Petitioners in WPC Nos. 2036 and 2074:
   • Raised concerns regarding specific actions taken by the Directorate of Technical Education and affiliated universities.
   • The petitioners themselves admitted that subsequent developments had rendered the matters irrelevant, leading to their requests for dismissal.

Issues

1. Whether the court could grant any meaningful relief in matters where the issues raised have become moot.
2. Whether there were any residual rights or grievances that still needed judicial determination.

Petitioner’s Arguments

• In WPC Nos. 2036 and 2074, the petitioners conceded that the cases had become infructuous due to the resolution of underlying issues or changes in circumstances. They submitted that no further adjudication was necessary.
• No arguments were advanced by the petitioners in WPC Nos. 2035 and 2037, as they were absent during the hearing.

Respondent’s Arguments

• In WPC Nos. 2035 and 2037, the UGC’s counsel asserted that the petitions had no subsisting relevance and should be dismissed as infructuous.
• The State and other respondents in all four petitions supported the dismissal, emphasizing that the court’s intervention was unnecessary.

Analysis of the Law

The court relied on the established principle that a writ petition is liable to be dismissed as infructuous when:

1. The relief sought is no longer applicable due to a change in circumstances.
2. The underlying issues have been resolved or rendered irrelevant, leaving no live controversy for the court to adjudicate.

The High Court’s approach aligns with Article 226 of the Constitution of India, which grants courts the power to issue writs for the enforcement of rights. However, such powers are discretionary and not to be exercised for academic or moot issues.

Precedent Analysis

While the court did not cite specific judgments, the dismissal is consistent with judicial precedents where courts have refused to entertain petitions when:

1. The issue at hand no longer affects the parties (e.g., Union of India v. S.S. Ahluwalia).
2. The matter has become academic and does not require a judicial pronouncement (e.g., Aligarh Muslim University v. Mansoor Ali Khan).

Court’s Reasoning

The court observed that both petitioners and respondents confirmed the irrelevance of the issues raised in the petitions:

1. In WPC Nos. 2035 and 2037, the UGC clarified that the petitions were moot, making judicial intervention redundant.
2. In WPC Nos. 2036 and 2074, the petitioners themselves acknowledged that no relief was required.

The court emphasized the principle of judicial efficiency, refraining from deciding cases that do not involve live controversies or enforceable rights.

Conclusion

The High Court dismissed all four writ petitions as infructuous, stating that there was no longer any purpose in continuing the litigation. The court’s orders were procedural, based on the acknowledgment by the parties that the cases had lost their relevance.

Implications

1. Judicial Efficiency: The dismissal reflects the court’s commitment to focusing its resources on disputes requiring immediate attention, avoiding academic discussions.
2. Procedural Clarity: The decision underscores the importance of timely updates by parties to ensure that the judiciary is not burdened with irrelevant matters.
3. Precedential Value: The judgment reaffirms that courts will not engage in adjudicating issues that are moot, thus reinforcing the principle of avoiding unnecessary judicial interference.

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