Chhattisgarh High CourtEducation LawConstitutional Law

Challenge to exclusion from 2025–26 school sports competitions became infructuous after the session ended.

SUO MOTOv.UNION OF INDIA

Challenge to exclusion from 2025–26 school sports competitions became infructuous after the session ended.. SUO MOTO vs UNION OF INDIA. Chhattisgarh High Court. LawLens
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In brief

The question

Whether the challenge to the order dated 3 June 2025, concerning participation in the 2025–26 sports session, remained justiciable after the expiry of that sports session.

The court held

The High Court held that the petition had become infructuous because the 2025–26 sports session was over and that the remaining issue had become academic.

It also directed

It accordingly disposed of WPPIL No. 66 of 2025, leaving it open to the parties to raise their grievances in a separate proceeding, to be considered and decided in accordance with law.

No declaration was made regarding the constitutional validity of the impugned order or the entitlement of CBSE-affiliated-school students to participate in future State-organised sports competitions.

01Facts

The proceedings concerned an order dated 3 June 2025, bearing No. S.No./Ph.E./100/Misc/2025-2026/1161, which allegedly restricted or excluded students of CBSE-affiliated schools in Chhattisgarh from participating in State-organised school sports competitions.

¶ 1

Although the matter was initially filed as a writ petition, the Court observed that the petitioner appeared to have a personal interest and therefore lacked locus to maintain a PIL.

¶ 1

By order dated 30 July 2025, the Court took suo motu cognizance of the issue and converted the matter into a suo motu PIL/office reference, appointing counsel as amici curiae.

¶ 1

At the hearing, the learned amicus submitted that the impugned order related to the 2025–26 sports session, which had already concluded.

¶ 2

02Issues

i.Whether the challenge to the order dated 3 June 2025, concerning participation in the 2025–26 sports session, remained justiciable after the expiry of that sports session.

¶ 2

ii.Whether the Court should adjudicate the broader question of permitting CBSE-affiliated-school students to participate in State-organised school sports competitions despite the expiry of the relevant session.

¶ 1–3

iii.Whether the parties should be left at liberty to pursue their grievances in a separate proceeding.

¶ 3

03Law Applied

The Court applied the procedural doctrine that a proceeding becomes infructuous when the relief sought relates to an expired or concluded event and no effective or operative relief can ordinarily be granted.

¶ 3

Courts generally do not decide purely academic or hypothetical questions in such circumstances, unless a live and recurring controversy requiring adjudication remains.

¶ 3

The Court also applied the principle that a party’s grievance may be left open for determination in an appropriate subsequent proceeding where the present proceeding has become infructuous.

¶ 3

Although the petition invoked Articles 14, 19(1)(g), 21 and 21A of the Constitution, the Court did not adjudicate the constitutional validity of the impugned policy or order.

¶ 1

04Reasoning

The reliefs sought were directed substantially against the operation of the impugned order during the 2025–26 sports session.

¶ 2–3

Since that session had already ended, an order permitting participation in competitions for that session could no longer have practical effect.

¶ 2–3

The Court therefore treated the controversy as infructuous and considered the constitutional and policy issues raised by the petition to be academic in the circumstances.

¶ 2–3

Without expressing a final view on the legality of excluding CBSE students or on the merits of the constitutional claims, the Court preserved the parties’ liberty to raise the grievance in an independent proceeding.

¶ 2–3

05Holding

The High Court held that the petition had become infructuous because the 2025–26 sports session was over and that the remaining issue had become academic.

¶ 3

It accordingly disposed of WPPIL No. 66 of 2025, leaving it open to the parties to raise their grievances in a separate proceeding, to be considered and decided in accordance with law.

¶ 3

No declaration was made regarding the constitutional validity of the impugned order or the entitlement of CBSE-affiliated-school students to participate in future State-organised sports competitions.

¶ 3
Chhattisgarh High Court

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SUO MOTOvsUNION OF INDIA

Chhattisgarh High Court · September 01, 2026

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