Facts
WPPIL No. 62 of 2021 and WPPIL No. 75 of 2022 concerned alleged large-scale financial irregularities, wastage, and manipulation of records in the procurement of paddy in Chhattisgarh during the marketing years 2018–2019, 2019–2020, and 2020–2021.
Source reference: para. 3The petitioners in WPPIL No. 75 of 2022 alleged losses involving approximately 3,067 metric tonnes valued at Rs. 5.38 crores, 43,656 metric tonnes valued at Rs. 79.54 crores, and 1,76,416 metric tonnes valued at Rs. 330.78 crores, respectively.
Source reference: para. 3They sought production of procurement records, an independent enquiry, fixation of personal liability, criminal prosecution of responsible persons, and recovery of the alleged losses.
Source reference: para. 3Since both petitions raised the same issue, the High Court clubbed them and treated WPPIL No. 75 of 2022 as the lead matter.
Source reference: para. 1During the hearing, the petitioners submitted that a new Procurement Policy had been introduced and enforced by the State Government for subsequent years, rendering the petitions infructuous; the respondents did not dispute this submission.
Source reference: paras. 4–5Issues
Whether the subsequent introduction and enforcement of a new Procurement Policy rendered the grievances and reliefs sought in the petitions academic and incapable of effective adjudication.
Source reference: paras. 4–6Whether any effective or efficacious relief could still be granted in relation to the alleged irregularities in the earlier paddy-procurement years.
Source reference: para. 6Law Applied
The Court applied the procedural doctrine that a proceeding may be dismissed as infructuous where subsequent events eliminate the surviving grievance or make the relief sought academic.
Source reference: para. 6The Court further applied the principle that judicial relief must be effective and efficacious; where no meaningful relief can be granted because of a subsequent change in circumstances, the Court need not adjudicate an otherwise academic dispute.
Source reference: para. 6No specific statutory provision or judicial precedent was relied upon in the order.
Source reference: no citationReasoning
The Court noted that the petitions challenged alleged deficiencies in the earlier paddy-procurement framework and sought directions concerning procurement administration, accountability, enquiry, and recovery.
Source reference: para. 3The subsequent implementation of a new Procurement Policy altered the governing framework for later procurement years.
Source reference: para. 6As the petitioners themselves accepted that the new policy rendered the petitions infructuous, and the respondents did not contest that position, the Court concluded that the original grievance no longer survived for consideration and that the requested directions had become academic.
Source reference: paras. 4–6Consequently, there was no effective or efficacious relief that could be granted in the pending proceedings.
Source reference: para. 6Holding
The High Court held that, in view of the subsequent introduction and enforcement of the new Procurement Policy, the grievances raised in both petitions no longer survived and the reliefs sought had become academic.
WPPIL No. 62 of 2021 and WPPIL No. 75 of 2022 were therefore dismissed as having become infructuous.
Source reference: para. 7Original Court PDF
MAMTA SHARMAvsSTATE OF CHHATTISGARH
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