Scope of Judicial Review in PIL Limited Upon Executive Compliance via Specialized Inquiry Committee

The petitioner filed a Public Interest Litigation (PIL) seeking the disbursement of agricultural input subsidy/compensation under SDRF/NDRF norms for farmers in Sahebganj Block, Muzaffarpur.

It was alleged that excessive rainfall from ‘Montha Cyclone’ on 02.10.2025 destroyed paddy crops across 4,552 hectares.

The petitioner claimed that although assessment reports were sent to the State on 05.12.2025, compensation was withheld because the online Direct Benefit Transfer (DBT) portal never opened for the specific block.

Following court orders dated 12.05.2026 and 14.05.2026, the State formed a Three-Member Committee to conduct field inspections and verify claims.

1. Whether the State respondents failed to discharge their duty in identifying eligible farmers and disbursing compensation for crop loss caused by the 2025 rainfall.

2. Whether the Court can conduct a further roving inquiry into the petitioner’s allegations after a government-constituted committee has submitted a verification report.

The court applied the settled legal principles governing Public Interest Litigation (PIL), emphasizing that such litigation is not adversarial but intended for the "interest of the Public at large".

The court further applied the principle of judicial restraint in administrative matters, holding that a Writ Court cannot embark on "fishing and roving inquiries" into unsubstantiated allegations once a competent authority has conducted a field assessment and submitted findings.

The relief mechanism was governed by the State Disaster Response Fund (SDRF) and National Disaster Response Fund (NDRF) norms for crop loss compensation.

The Court noted that the State had complied with previous judicial directions by constituting a Three-Member Committee on 13.05.2026.

The Committee conducted field inspections, reviewed contemporaneous records (photographs, official reports, and applications), and identified 56,152 eligible beneficiaries out of 66,073 applicants and Rs. 33,21,51,844/- had been transferred via DBT.

Regarding the petitioner's claim of technical portal issues in Sahebganj, the Court found that the Committee had already re-examined the revised district assessment and found no further authenticated beneficiaries.

The Court reasoned that since a formal inquiry was conducted and findings were submitted, it would be inappropriate for a Writ Court to act as an investigating agency for unsubstantiated claims.

The PIL was dismissed; however, the Court granted the petitioner liberty to address specific grievances before the concerned statutory authorities if necessary and all pending interlocutory applications were disposed of accordingly.