Writ of Mandamus cannot be issued for purely private disputes or to compel registration of criminal cases.

The petitioner, proprietor of M/S Ananta Enterprises, alleged the loss of three cheques and filed a police complaint on November 5, 2025.

Subsequently, he discovered one cheque for ₹80,000/- was used to pay the electricity dues of a third party (Respondent No. 5).

The petitioner claimed fraudulent misuse of the instruments and alleged collusion between the Electricity Department and the private respondent.

Seeking administrative action and the resolution of complaints filed via the Chief Minister's Portal, the petitioner approached the High Court for a writ of mandamus after the respondent authorities failed to act.

1. Whether a writ of mandamus can be issued to compel administrative authorities to resolve a complaint involving criminal allegations when statutory remedies are available.

2. Whether the petitioner established a clear legal right and a corresponding statutory duty on the part of the respondents to warrant judicial intervention under Article 226.

The court applied the principles governing Article 226 of the Constitution of India regarding the issuance of a writ of mandamus.

A petitioner must demonstrate a clear, enforceable legal right and a corresponding public or statutory duty.

Hardik Pravin Kumar Shah v. Union of India regarding the extraordinary nature of the writ.

Union of India v. S.B. Vohra regarding judicial discretion.

Oriental Bank of Commerce v. Sunder Lal Jain which establishes that mandamus cannot be used to enforce purely private rights or contractual obligations.

Statutory scheme for investigation under Chapter XIII of the Bharatiya Nagarik Suraksha Sanhita (B.N.S.S.), 2023.

The court observed that for a writ of mandamus to be maintainable, the applicant must satisfy specific conditions, including the existence of a legal right and the absence of an alternative remedy.

In this instance, the court found the petitioner failed to identify any statutory provision that obligated the electricity or administrative officials to adjudicate criminal complaints on an administrative side.

The court reasoned that mandamus is a discretionary remedy intended to supply a deficiency in law, not to supplant ordinary civil or criminal remedies.

Since the grievance essentially concerned the non-registration of a criminal case and alleged fraud, the court determined that the petitioner had an efficacious alternative remedy under Chapter XIII of the B.N.S.S., 2023.

The court emphasized that it does not function as a court of appeal to reassess factual matters or resolve purely private disputes through prerogative writs.

The writ petition was dismissed as not maintainable, with liberty to the petitioner to pursue the appropriate statutory remedies for criminal investigation as provided under the B.N.S.S., 2023.