Chhattisgarh High Court
Administrative and Public LawCivil Procedure and Evidence

Chhattisgarh High Court dismisses PIL alleging ₹415 crore paddy procurement losses as infructuous after new policy introduced

MAMTA SHARMA vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: September 03, 20262 MIN READSOURCE JUDGMENT
Chhattisgarh High Court dismisses PIL alleging ₹415 crore paddy procurement losses as infructuous after new policy introduced. MAMTA SHARMA vs STATE OF CHHATTISGARH. Chhattisgarh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

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. 3

The 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. 3

They 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. 3

Since 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. 1

During 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. 4–5
02

Issues

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. 4–6

Whether any effective or efficacious relief could still be granted in relation to the alleged irregularities in the earlier paddy-procurement years.

Source reference: para. 6
03

Law 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. 6

The 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. 6

No specific statutory provision or judicial precedent was relied upon in the order.

Source reference: no citation
04

Reasoning

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. 3

The subsequent implementation of a new Procurement Policy altered the governing framework for later procurement years.

Source reference: para. 6

As 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. 4–6

Consequently, there was no effective or efficacious relief that could be granted in the pending proceedings.

Source reference: para. 6
05

Holding

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. 7
Chhattisgarh High Court

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MAMTA SHARMAvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · September 03, 2026

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