Challenge to restoration became infructuous after the underlying revenue proceedings were dismissed.

The petitioner challenged the Sub-Divisional Officer’s order dated 23 July 2021 restoring, suo motu, revenue proceedings under Section 170-B of the Chhattisgarh Land Revenue Code, 1959.

Those proceedings had earlier been dismissed for want of prosecution on 9 March 2020, and the petitioner contended that respondent No. 4 had filed no restoration application.

During the writ petition, the State reported that a review of the record found no restoration application and that the revenue case had been dismissed by a further order dated 17 January 2025.

Respondent No. 4 agreed that no effective relief remained.

Whether the challenge to the 23 July 2021 restoration order remained capable of effective adjudication after the underlying revenue case was dismissed on 17 January 2025

Whether the Court should examine the legality of the restoration order despite the subsequent dismissal of the revenue proceedings

The Court applied the principle that a proceeding may be dismissed as infructuous where subsequent events leave no effective relief for the Court to grant.

Section 170-B of the Chhattisgarh Land Revenue Code, 1959, was mentioned as the basis of the underlying revenue proceedings.

The petitioner’s grievance concerned the revival of revenue proceedings by the 23 July 2021 order.

However, the State confirmed that the revenue authority had found no restoration application on record and had subsequently dismissed the revenue case on 17 January 2025.

Because the proceedings sought to be revived had therefore come to an end, the Court concluded that reviewing the restoration order would serve no practical purpose.

It consequently did not determine the order’s legality on the merits.

It expressly stated that it had formed no opinion on the merits of the original proceedings or on the parties’ rights and contentions concerning them.