LATE SHRI RAMAVATAR GARG SON OF LATE SHRI HANUMAN PRASAD GARG vs. ASSISTANT COMMISSIONER OF INCOME TAX

Facts

The petitioners, legal heirs of deceased individuals (Late Jwala Prasad Sarda, Late Shri Prakash Chand Daga, and Late Shri Ramavatar Garg), filed several writ petitions before the Rajasthan High Court, Jaipur Bench. The respondent in all these petitions was the Assistant Commissioner of Income Tax, Central Circle-4, Jaipur. The petitions challenged orders or actions taken by the Income Tax Department. The specific assessment years and the exact nature of the orders under challenge are not detailed in the provided text. The procedural history indicates that these writ petitions were filed and subsequently came up for hearing.

Held

The High Court held that the writ petitions had become infructuous. The counsel for the petitioners made a submission to this effect. Based on this submission, the Court proceeded to dismiss the writ petitions. The reasoning is that if the parties themselves acknowledge that the matter is no longer a live dispute, and the relief sought is no longer capable of being granted or is otherwise rendered moot by the passage of time, the court will not adjudicate on the merits. The ratio decidendi is that writ petitions that have become infructuous are to be dismissed as such. The operative direction was the dismissal of all the writ petitions.

Key Issues

The primary issue before the High Court was whether the writ petitions had become infructuous due to the efflux of time. The petitioners' counsel submitted that the petitions were indeed infructuous. The respondent revenue's contentions are not recorded in the judgment. The question of law, therefore, is whether a writ petition can be dismissed as infructuous when the underlying dispute has become moot due to the passage of time or other supervening circumstances, without deciding the merits of the case. This turns on the court's discretion to entertain matters that are no longer live controversies.