Chhattisgarh High CourtAdministrative and Public LawCivil Procedure and Evidence

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

RAJ KUMAR MISHRAv.STATE OF CHHATTISGARH

A PIL becomes infructuous and is dismissed when the underlying grievance has been redressed.. RAJ KUMAR MISHRA vs STATE OF CHHATTISGARH. Chhattisgarh High Court. LawLens
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In brief

The question

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

The court held

The Court dismissed WPPIL No. 69 of 2021 as having become infructuous

It also directed

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

01Facts

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

¶ 2

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

¶ 3

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

¶ 4

02Issues

i.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

¶ 3, 6–7

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

¶ 6–8

03Law Applied

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

¶ 7

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

¶ 8

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

¶ 2

04Reasoning

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

¶ 6

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

¶ 3

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

¶ 4

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

¶ 7

05Holding

The Court dismissed WPPIL No. 69 of 2021 as having become infructuous

¶ 8

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

¶ 8
Chhattisgarh High Court

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RAJ KUMAR MISHRAvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · September 02, 2026

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