Rajasthan HC Dismisses Assistant Professor’s PIL Challenging VC’s Reappointment As Personal Vendetta, Imposes ₹1 Lakh Costs For Undisclosed Criminal Cases

The petitioner filed a public interest litigation challenging Section 11(1) of the Sardar Patel University of Police, Security and Criminal Justice, Jodhpur Act, 2012, and the advertisement and appointment of Dr. Alok Tripathi as Vice-Chancellor.

The respondents objected that the petition was not maintainable because the petitioner had failed to disclose his civil, revenue and criminal litigation as required by Rule 385-F of the Rajasthan High Court Rules, 1952.

The Court noted that the petitioner, a former Assistant Professor at the University, had filed the PIL after proceedings—including criminal complaints and disciplinary proceedings—had been initiated against him during Dr. Tripathi’s tenure. It found that the petitioner had not disclosed those proceedings in the petition.

Rule 385-F of the Rajasthan High Court Rules, 1952 requires a PIL petitioner to disclose, among other matters, whether they have been involved in civil, revenue or criminal litigation and, if so, complete details of that litigation.

The Court treated this disclosure obligation as mandatory and material to assessing the petitioner’s bona fides and credibility.

PIL jurisdiction is intended to address genuine public wrongs, not to advance personal grievances or collateral objectives; courts must guard against its misuse (Dr. B. Singh v. Union of India, (2004) 3 SCC 363; Jaipur Shahar Hindu Vikas Samiti v. State of Rajasthan, (2014) 5 SCC 530).

The Court accepted that quo warranto may be sought by any person, but held that this does not dispense with the requirements governing a PIL under the High Court Rules.

The Court considered the petitioner’s failure to disclose his litigation alongside the timing and circumstances of the petition.

It found that he had not challenged Dr. Tripathi’s earlier appointment in 2020 under the same rules, but brought the PIL after proceedings had been initiated against him and upon the Vice-Chancellor’s reappointment in 2024.

The Court rejected the argument that the proceedings need not be disclosed because they were initiated by or at the instance of the Vice-Chancellor; Rule 385-F required disclosure regardless of who initiated them or the alleged merits of the cases.

The Court concluded that the nondisclosure and surrounding circumstances showed lack of bona fides and misuse of PIL jurisdiction.

It dismissed the petition with costs of ₹1,00,000, payable to the Rajasthan State Legal Services Authority.

The Court expressly left open the constitutional validity of Section 11(1) and did not decide the merits of the challenge to the advertisement or appointment.