Writ Jurisdiction Inappropriate Where Disputed Questions of Fact Require Adjudication Through Alternative Statutory Remedies

The petitioner filed a writ petition under Article 226 of the Constitution of India challenging the appointment of Respondent No. 3 as an Anganwadi Worker in Ward No. 2, Nagar Panchayat Kailaras, District Morena.

The petitioner, who was on the waiting list, alleged that Respondent No. 3 was appointed despite never submitting an application for the post.

Conversely, the State respondents contended that Respondent No. 3 was more meritorious than the petitioner and that the petitioner had failed to exhaust the alternative remedy of filing an appeal before the Collector.

1. Whether the High Court should exercise its extraordinary writ jurisdiction under Article 226 when the case involves disputed questions of fact regarding the recruitment process.

2. Whether the petitioner’s claim regarding the non-submission of an application by Respondent No. 3 can be adjudicated solely on the basis of affidavits.

The Court applied the settled principle that writ jurisdiction under Article 226 is not intended for the adjudication of "hotly disputed questions of facts".

It relied on Chairman, Grid Corporation of Orissa Ltd. (GRIDCO) & Others v. Sukamani Das (Smt.), which held that where negligence or facts are denied, the proper remedy is a civil suit rather than a writ petition.

It further cited S.P.S. Rathore v. State of Haryana, Shubhas Jain v. Rajeshwari Shivam, and M.P. Power Management Co. Ltd. v. Sky Power Southeast Solar India (P) Ltd., reinforcing that while no absolute bar exists, the Court should relegate parties to alternative forums or civil courts when resolution requires a comparative assessment of conflicting evidence or demystifying documents.

The Court observed that the primary dispute—whether Respondent No. 3 actually applied for the post—is a factual controversy.

The State’s reply explicitly contradicted the petitioner’s claim, asserting that Respondent No. 3 was more meritorious and had followed the application procedure.

Applying the precedents from GRIDCO and M.P. Power Management, the Court reasoned that such disputed questions cannot be resolved based on competing affidavits alone in a writ proceeding.

Furthermore, the Court noted that the petitioner bypassed the statutory alternative remedy of an appeal before the Collector.

Since the matter lacked a "pure legal flavor" and required factual verification of recruitment records, it was deemed unfit for summary adjudication under Article 226.

The Court answered that the High Court should not intervene when alternative forums are available to resolve factual disputes.

However, the petitioner was granted liberty to approach the appropriate forum (such as the appellate authority or civil court) in accordance with the law.