A PIL becomes infructuous and is dismissed when the underlying grievance has been redressed.

The petitioner, an RTI activist, filed a Public Interest Litigation seeking judicial intervention for the expeditious and time-bound consideration and disposal of pending complaints against 45 IAS officers. He sought disclosure of the status of the complaints and investigations, prescription of timelines for their disposal, and initiation and completion of disciplinary proceedings under the All India Services (Discipline and Appeal) Rules, 1969

The State submitted that appropriate action had already been taken regarding the complaints and that the relief sought no longer survived, rendering the petition infructuous

Appearing in person through video conferencing, the petitioner accepted the State’s submission and agreed that no further relief remained for consideration

1. Whether the petition had become infructuous in view of the subsequent action taken by the respondents and the redressal of the petitioner’s grievance

2. Whether any further effective relief or adjudication on the merits of the complaints against the IAS officers survived for consideration

The Court applied the procedural principle that a writ petition becomes infructuous where the grievance forming its foundation has been substantially redressed and no effective relief remains to be granted

The Court also followed the settled restraint that, once proceedings are disposed of as infructuous, the Court need not adjudicate the merits of the underlying dispute; accordingly, it expressly declined to express any opinion on the complaints or proceedings initiated pursuant to them

Although the petitioner referred to the All India Services (Discipline and Appeal) Rules, 1969, the Court did not determine or apply any substantive provision of those Rules

The principal relief sought concerned alleged inaction and delay in dealing with complaints against the IAS officers

The respondents represented that appropriate steps had already been taken, thereby addressing the basis of the PIL

The petitioner did not dispute that position and expressly acknowledged that no further relief survived

In light of the redressal of the grievance and the absence of any surviving effective relief, the Court held that continuing adjudication was unnecessary and treated the petition as infructuous

It clarified that the dismissal did not constitute any opinion on the merits of the complaints against the concerned IAS officers or on any proceedings initiated pursuant to them