Mandamus seeking consideration of representation becomes infructuous upon decision by the competent authority.

The applicant, a Section Associate at Visvesvaraya Iron and Steel Plant (VISL), sought a mandamus to compel Respondents 2 to 4 to consider his request for a compassionate transfer to the Bokaro Steel Plant pursuant to the transfer policy dated October 8, 2020.

During the proceedings, the Tribunal observed that Respondent Nos. 2 to 4 provided false statements and contradictory memos regarding the status of the applicant’s request on their internal CARE portal.

Consequently, on February 20, 2026, the Tribunal issued a show-cause notice to initiate contempt and perjury proceedings against the respondents for misleading the Bench and undermining its authority.

Respondents subsequently filed affidavits tendering unconditional apologies, explaining the discrepancies as "confusion," and updated the portal to reflect that the Compassionate Transfer Committee (CTC) had officially rejected the applicant's request on February 17, 2026.

1. Whether the respondents’ failure to consider the applicant's transfer request under the 2020 policy constituted arbitrary inaction warranting judicial intervention.

2. Whether the contempt and perjury proceedings initiated against the respondents for misleading the Tribunal should be finalized or closed following their unconditional apology.

3. Whether the OA survived for consideration after the respondents updated the status of the transfer application during the pendency of the litigation.

The court exercised jurisdiction under Section 19 of the Administrative Tribunals Act, 1985.

It applied the principle that statements made before a court carry legal sanctity and that providing false undertakings or misleading submissions constitutes a deliberate interference with the administration of justice, punishable as contempt or perjury.

Furthermore, the court applied the doctrine of "infructuous" litigation, where a case is dismissed because the primary relief sought has already been addressed or superseded by subsequent events.

The Tribunal initially found a prima facie case of professional misconduct and abuse of process because the respondents’ oral submissions and memos contradicted their own digital records (the CARE portal).

However, upon the filing of affidavits by high-ranking officials (including the Chairman of SAIL and Executive Directors) tendering unconditional apologies and explaining the administrative "confusion," the Tribunal opted to maintain judicial decorum by closing the contempt proceedings.

Regarding the merits of the OA, the Tribunal noted that the applicant's grievance was "inaction".

Since the respondents eventually performed the act of "considering" the application—resulting in a "Not recommended" status on February 17, 2026—the prayer for a mandamus to consider the request was effectively satisfied, albeit with an unfavorable outcome.

The contempt and perjury proceedings were closed with a warning to the respondents to refrain from repeating such conduct.

The OA was disposed of with liberty granted to the applicant to challenge the CTC’s decision not to recommend his transfer in a fresh proceeding.

Despite finding grounds for exemplary costs, the Tribunal took a lenient view and ordered that costs be made easy.