High Court may relegate parties to alternative grievance redressal mechanisms despite pending writ proceedings involving factual disputes.

The Appellants traveled from New Delhi to San Francisco via Air India on November 11, 2020. They alleged that despite disclosing medical conditions (diabetes and hypertension), the airline served inadequate meals and pre-packed snacks, leading to Appellant No. 1 suffering food poisoning and hypoglycemic episodes

The Appellants filed a Writ Petition seeking an independent committee to review food quality and regulatory oversight

A Single Judge disposed of the petition on April 8, 2025, directing the Ministry of Civil Aviation (R-1) to treat the petition as a formal grievance for redressal

The Appellants subsequently filed recall applications alleging non-compliance and bias (as DGCA was both a respondent and the adjudicator), which were dismissed on July 8 and December 22, 2025

The Appellants challenged these orders via the present intra-court appeal

1. Whether the learned Single Judge erred in relegating the Appellants to an alternative administrative remedy instead of adjudicating the Writ Petition on merits after having earlier entertained the matter.

2. Whether the grievance redressal process by Respondent Nos. 1 and 2 violated principles of natural justice given their status as parties to the original litigation.

The court applied the principle that while the High Court’s jurisdiction under Article 226 of the Constitution is not ousted by an alternative remedy, it should be exercised sparingly as per State of U.P. v. U.P. Rajya Khanij Vikas Nigam Sangharsh Samiti, which held that a writ petition can be dismissed on grounds of alternative remedy even after admission

It further relied on U.P. State Bridge Corpn. Ltd. v. U.P. Rajya Setu Nigam S. Karamchari Sangh, establishing that delay in disposal does not preclude relegation to an alternative forum, especially where factual controversies require resolution

The Court reasoned that merely issuing notice or seeking instructions does not constitute a final exercise of writ jurisdiction that mandates a decision on merits

It noted that the dispute involves "disputed questions of fact" regarding food quality and medical care that the regulatory authorities (Ministry of Civil Aviation and DGCA) are better equipped to investigate as experts

Regarding the allegation of bias or violation of natural justice, the Court found the Appellants' apprehensions premature, noting that the Single Judge had already reserved the Appellants' liberty to challenge the outcome of the administrative process if it proved unsatisfactory

The Court emphasized that administrative regulators are the appropriate first instance for systemic grievances in the aviation sector

The Court directed Respondent Nos. 1 and 2 to expeditiously conclude the grievance redressal exercise within six weeks by passing a reasoned order after considering submissions from both the Appellants and Air India

Liberty was reiterated for the Appellants to seek fresh legal remedies if aggrieved by the final administrative decision