Use of “Siddhanta” does not invalidate a no-confidence resolution conveying requisitionists’ clear intent.

The petitioner, Sarpanch of Badatika Gram Panchayat, challenged the initiation of a no-confidence motion against him under Section 24 of the Orissa Gram Panchayats Act, 1964.

The challenge was based on the contention that the resolution dated 22 May 2025, relied upon for initiating the process, was not a legally valid “proposed resolution” because it used the vernacular word “Siddhanta”, allegedly signifying a decision already taken rather than a proposal to be considered.

The petitioner sought to invalidate the consequential notice and the no-confidence proceedings.

By an interim order dated 2 September 2025, the Court permitted the motion to be put to vote but directed that its result not be published.

The State and the requisitionists opposed the petition, relying principally on Smt. Gunduri Singh v. State of Odisha.

1. Whether the resolution dated 22 May 2025 constituted a valid proposed resolution and requisition for initiating a no-confidence motion under Section 24 of the Orissa Gram Panchayats Act, 1964, notwithstanding the use of the word “Siddhanta”?

2. Whether the use of the word “Siddhanta” rendered the subsequent notice and no-confidence proceedings void or non est in law?

3. Whether the interim order restraining publication of the result should continue?

The Court applied Section 24 of the Orissa Gram Panchayats Act, 1964, which requires a no-confidence meeting to be convened on the basis of a requisition signed by at least one-third of the total membership and accompanied by a copy of the proposed resolution; the motion must be considered in a specially convened meeting and supported by the prescribed majority.

The Court considered the Full Bench decision in Nabanita Kapat Patra v. Collector, 2025 SCC OnLine Ori 4218, which recognises the resolution and requisition as preconditions for initiating a no-confidence motion.

It also relied on Smt. Gunduri Singh v. State of Odisha, 2026 SCC OnLine Ori 3705, which held that the use of the word “Siddhanta” does not, by itself, invalidate a resolution when the document, read as a whole, clearly conveys the requisitionists’ intention to initiate a no-confidence motion.

The Court accepted that “Siddhanta” may, in its dictionary sense, refer to a final decision or conclusion.

However, validity depended on the substance and overall meaning of the document rather than on the isolated use of that word.

Applying Gunduri Singh, the Court held that the impugned resolution unambiguously conveyed the requisitionists’ intention to initiate the no-confidence process against the petitioner.

Since the resolution satisfied the statutory requirement under Section 24 when read in its entirety, the Court rejected the argument that it represented a concluded decision and therefore could not constitute a proposed resolution.

Consequently, the notice and subsequent proceedings were not rendered void.

The writ petition was dismissed for lack of merit.

The interim order was vacated.

The authorities were directed to publish the result of the no-confidence motion, stated to have already been held, and take consequential steps in accordance with law.

Costs were made easy.