Madras High Court
Administrative and Public LawCivil Procedure and Evidence

Writ petition becomes infructuous upon compliance with the relief sought during its pendency.

R.Kalyanasundaram vs The State of TamilNadu

Madras High CourtJUDGMENT: August 20, 20262 MIN READSOURCE JUDGMENT
Writ petition becomes infructuous upon compliance with the relief sought during its pendency.. R.Kalyanasundaram vs The State of TamilNadu. Madras High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner, R. Kalyanasundaram, sought a writ of mandamus directing Respondents 2 and 3 to step up his pay from ₹55,700 to ₹57,400, grant annual increments from 2020 on par with his juniors, and prepare a fresh proposal for revision of his pay, salary arrears and pension in accordance with Government Letter (Ms.) No. 83 dated 6 February 2019.

Source reference: p.1–2

He further sought that the revised proposal be forwarded to the Accountant General for sanction of pension, after considering his representation dated 11 May 2020.

Source reference: p.1–2

During the pendency of the writ petition, the petitioner’s counsel submitted that the relief sought had been complied with.

Source reference: p.3
02

Issues

Whether the petitioner was entitled to a direction for stepping up of pay from ₹55,700 to ₹57,400, with annual increments from 2020, on par with his juniors under Government Letter (Ms.) No. 83 dated 6 February 2019.

Source reference: p.1–2

Whether the respondents were required to prepare and forward a revised proposal concerning the petitioner’s pay, arrears and pension to the Accountant General for sanction of pension.

Source reference: p.2

Whether any further relief survived after the respondents complied with the petitioner’s prayer during the pendency of the writ petition.

Source reference: p.3
03

Law Applied

The petition was filed under Article 226 of the Constitution of India, invoking the High Court’s jurisdiction to issue a writ of mandamus for performance of a public or statutory duty.

Source reference: p.1

The petitioner relied upon Government Letter (Ms.) No. 83 dated 6 February 2019 concerning pay stepping-up and consequential pensionary benefits.

Source reference: p.2

However, the Court did not adjudicate the substantive entitlement under that Government Letter or rely on any precedent; it applied the procedural principle that when the relief sought in a writ petition has been voluntarily or administratively complied with during its pendency, no effective controversy remains for adjudication.

Source reference: no citation
04

Reasoning

The Court heard the petitioner’s counsel, the Government Advocate for Respondents 1 to 3, and the Standing Counsel for Respondent 4.

Source reference: p.2

Since the petitioner expressly stated that the relief claimed had been complied with during the pendency of the proceedings, the Court found that the original grievance had become moot.

Source reference: p.3

Consequently, it did not examine the merits of the claim for pay stepping-up, annual increments, arrears or pension, and treated no further adjudication as necessary.

Source reference: p.3
05

Holding

The Court accepted the petitioner’s submission that the relief had been complied with and held that nothing further survived in the writ petition.

The writ petition was accordingly disposed of, without costs.

Source reference: p.3
Madras High Court

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R.KalyanasundaramvsThe State of TamilNadu

Madras High Court · August 20, 2026

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