Internal audit slips addressed to administrative heads do not constitute a cause of action for writ proceedings.

The petitioner, a Junior Assistant at the Fast Track Mahila Court, Theni, was appointed on compassionate grounds in 2015.

He filed a Writ of Certiorari under Article 226 of the Constitution to quash Audit Slip No. 1, dated 22.06.2023, issued by the Internal Audit Wing of the Madurai Bench of the Madras High Court.

The audit slip raised objections regarding the petitioner’s pay fixation and was addressed to the Sessions Judge, Fast Track Mahila Court, Theni, rather than the petitioner himself.

1. Whether an internal audit slip addressed to a departmental head constitutes a valid cause of action for instituting writ proceedings under Article 226.

2. Whether the petitioner was entitled to challenge a document that was not officially communicated to him.

The court applied the fundamental principle of writ jurisdiction that a writ petition is only maintainable when there is a concrete "cause of action" or a final order affecting the legal rights of the petitioner.

The court emphasized that internal administrative notes or audit objections are preparatory in nature and do not, by themselves, constitute an actionable injury until the competent authority takes an final decision based on such notes.

The court reasoned that the impugned Audit Slip was merely a communication from the Internal Audit Wing to the Sessions Judge for consideration and appropriate decision-making.

Since no final action or recovery had been initiated against the petitioner based on that slip, it did not provide a cause of action for judicial review.

Furthermore, the court expressed concern over how the petitioner obtained a copy of an internal audit document not addressed to him, leading the court to conclude that the writ was premature and lacked a legal basis.

The Writ Petition was dismissed, and the connected miscellaneous petitions were closed; additionally, the court directed the Principal District Judge, Theni, to conduct an enquiry into how the internal audit slip was made available to the petitioner.