Factual Adjudication Can't Be Done In Writ Petition: Supreme Court Dismisses Nagam Janardhan Reddy’s Plea For CBI’s Investigation Into PRRLIS Project
The Supreme Court held that the High Court was justified in not exercising its discretion and jurisdiction to refer the matter to the CBI.
Justice B.V. Nagarathna, Justice Satish Chandra Sharma, Supreme Court
The Supreme Court dismissed the Special Leave Petition filed by Nagam Janardhan Reddy praying for CBI’s investigation into the Palamuru Ranga Reddy Lift Irrigation Project.
The Petitioner, a former Member of the Legislative Assembly and a holder of Ministerial positions in the erstwhile State of Andhra Pradesh, filed the Public Interest Litigation due to being aggrieved by the manner in which the estimates prepared for various works including for Electro Mechanical (E&M) equipments, in Palamuru Ranga Reddy Lift Irrigation Scheme (PRRLIS) were revised by not adhering to the public trust reposed in the authorities, thereby resulting in loss of sum of Rs.2426.07 crores to the public exchequer.
The Bench of Justice BV Nagarathna and Justice Satish Chandra Sharma held, “We have extracted the prayers sought for by the petitioner herein. As far as the first prayer is concerned, it is for a declaration that the action of respondent nos.1 to 7 was fraudulent in revising the estimates of the project in question. We find that those are aspects which would call for determination of facts or in other words, a factual adjudication which cannot be done in a writ petition filed under Article 226 of the Constitution of India.”
AOR Prashant Bhushan appeared for the Appellant, while Senior Advocates Vivek Reddy, Parag Tripathi, Gaurav Agarwal, Shailesh Madiyal and Mukul Rohatgi represented the Respondent.
Brief Facts
The Petitioner had filed a Writ Petition before the High Court for the State of Telangana and the State of Andhra Pradesh. The PIL sought a Writ, Order or Direction, more particularly one in the nature of Writ of Mandamus declaring the action of respondents 1 to 7 in fraudulently revising the value of Electro Mechanical (E&M) Equipments for Palamuru Ranga Reddy Lift Irrigation Scheme from Rs.5960.79 crores as estimated by Engineering Staff College of India to Rs.8386.86 crores by the Advisor and the Departmental Committee thereby causing loss of sum of Rs.2426.07 crores to the public exchequer and not taking any action on the representation made by the petitioner as illegal, unreasonable, arbitrary and capricious and consequently set aside all consequential actions of the respondents relating to PRRLIS for packages.
Court’s Reasoning
The Supreme Court noted, “We have considered the submissions advanced at the Bar. Primarily, we are on the question as to whether the High Court was justified in dismissing the writ petition having answered certain contentions raised by the petitioner herein as to whether the High Court ought to have exercised its discretion in granting the prayer(s) made by the petitioner herein.”
The Bench held, “Insofar as the second prayer for referring the matter to the CBI is concerned, we find that the High Court on considering the contentions raised by the petitioner herein has given its answer to the same and has declined to exercise its discretion to refer the matter to the CBI for the purpose of conducting an investigation and to submit a report to the Court. We find that the High Court was justified in not exercising its discretion and jurisdiction to refer the matter to the CBI. We do not think that in this Special Leave Petition, we can sit in judgment over the non-exercise of discretion in favour of the petitioner herein and consequently granting the prayer of the petitioner for referring the matter to the CBI for the conduct of an investigation.”
Consequently, the Court ordered, “In the circumstances, we are not inclined to consider this Special Leave Petition any further. Hence, the same is dismissed.”
Accordingly, the Supreme Court dismissed the SLP.
Cause Title: Nagam Janardhan Reddy v. State Of Telangana & Anr. (Neutral Citation: 2025 INSC 798)
Appearance:
Appellant: AOR Prashant Bhushan; Advocates Neha Rathi and Kajal Giri
Respondents: Senior Advocates Vivek Reddy, Parag Tripathi, Gaurav Agarwal, Shailesh Madiyal and Mukul Rohatgi; ASG K M Nataraj; AOR Sahil Tagotra, Devina Sehgal, Prithu Garg, Mukesh Kumar Maroria, et al; Advocates Trinath Tadakamalla, Nisha Bhatia, Shreya Kasera, Kumar Vaibhaw, Yatharth Kansal, Kanu Agarwal, et al