Public Interest Litigation Is Not Maintainable to Resolve Internal Committee Disputes or Administrative Decisions on Institutional Locations

The petitioner, claiming to be a social worker, filed a Public Interest Litigation (PIL) seeking a writ of mandamus to shift Madarsa Islamia Hathia Diyara (Madarsa No. 662) from its current location on Primary School premises to a newly constructed building on donated land in Mauza-Hariharpur

Though the Bihar State Madarsa Education Board directed the shift after the constitution of a new Managing Committee in 2022, the Madarsa continued to operate from the old site

The petitioner alleged that students were suffering due to an internal dispute between the 2008 and 2022 Managing Committees

The State respondents challenged the maintainability of the PIL, arguing it was a private interest matter dressed as public interest

1. Whether the writ petition seeking the shifting of a Madarsa is maintainable as a Public Interest Litigation

2. Whether the Court should interfere in administrative decisions regarding the location of educational institutions

The Court applied the principle that administrative authorities, not the judiciary, are responsible for determining the location of schools and health centers based on administrative considerations, as established in Harendra Pratap Singh v. The State of Bihar Ors. (C.W.J.C. No. 5363 of 1998)

It further relied on Brahmdeo Prasad Mahton v. The State of Bihar Ors. (CWJC No. 2105 of 2019), which held that a PIL does not lie for the implementation of a State's own administrative decisions as it is the State's duty to enforce them

Additionally, the Court applied the doctrine that a PIL is not maintainable if it stems from private or personal interests

The Court observed that the dispute was essentially an internal power struggle between an erstwhile Managing Committee and a newly appointed one, rather than a genuine matter of public concern

By reviewing the pleadings, the Court determined that the petitioner’s involvement indicated a "private interest" in the management of Madarsa No. 662

Following the precedents cited by the State, the Court reasoned that the location and shifting of institutions are matters of administrative policy, and since the Madarsa Board had already passed an order, it was for the administration to manage the situation

Judicial interference was deemed unwarranted as the litigation appeared to be an attempt to use the Court to resolve a local management conflict

The Court answered both issues in the negative, ruling that it would not interfere in administrative decisions of this nature and consequently, the writ petition was dismissed