Selection of sites for public institutions is an administrative function generally immune from judicial interference.

The District Institute of Education and Training (DIET) Centre was originally located within the DM College campus in Imphal West.

Due to a 2016 policy decision to upgrade DM College into a Deemed University, the State decided to shift the DIET Centre.

While Mayang Imphal was initially proposed and a foundation stone was laid, no construction commenced there.

Subsequently, the State issued an order dated 22.05.2021 to shift the Centre to Lamsang (Salam Mamang Leikai), citing better accessibility for students via National Highway 37 and Imphal–Kangchup Road.

The petitioner filed this PIL on 03.12.2021, primarily aggrieved that the new location falls outside the ‘23-Mayang Imphal Assembly Constituency’.

By the time of the final hearing, construction at the Lamsang site was at an advanced, near-complete stage.

1. Whether the executive decision to relocate a public institution (DIET Centre) based on administrative convenience is subject to judicial interference under Article 226 in the absence of compelling reasons.

2. Whether the preference for a specific Assembly Constituency constitutes a valid legal ground to set aside a policy decision regarding the location of a public building.

The Court held that the determination of where a public institute or office should be situated lies squarely within the realm of the executive arm of a welfare State.

Judicial interference in such administrative matters via PIL is an exception, permissible only when there are compelling reasons.

The Court relied on the precedent of Aleemuddin v. State of Uttar Pradesh Ors. (AIR 2019 SC 276), which established that the construction site of public buildings (such as a Tehsil building) is an administrative matter and not a fit subject for High Court determination under Article 226, particularly where the petitioner may have private interests in a specific location.

The Court observed that the State’s decision to choose Lamsang was based on relevant determinants, including motorable access and student comfort, whereas the Mayang Imphal site was found unsuitable for transportation.

The petitioner failed to provide any material demonstrating that the Lamsang site was undesirable or caused public inconvenience; the sole grievance was the change in Assembly Constituency.

The Court noted the petitioner’s admission of owning land near the originally proposed site, mirroring the factual matrix of Aleemuddin where private interests were disguised as public interest.

Furthermore, since construction at Lamsang was nearly complete using public funds, any judicial interference at this stage would result in significant financial loss to the State.

The Court concluded that the executive had revisited its earlier proposal for valid administrative reasons, and the petitioner showed no violation of law or public injury.

The Court found no merit in the contention that the institution must be situated within a specific Assembly Constituency.

Consequently, the prayer to direct the State to shift the construction back to Mayang Imphal was rejected, and no costs were imposed.