While observing that the Public Interest Litigation is not liable to be entertained once the Competent Authority has enquired into the matter and closed the same, the Madhya Pradesh High Court has imposed a cost of Rs 75,000 on an Advocate for filing three petitions challenging the appointment of the Chairman of the MP Private University Regulatory Commission.

The High Court also took note of the fact that the petitioner had filed the petitions on behalf of one of the respondents, Dr. Vishwas Chouhan, who happened to be a client in subsequent writ petitions.

The petition was filed by a practicing Advocate, claiming to be an LL.M. (Master of Laws) student, in the nature of a Public Interest Litigation against the respondents-Authorities of the Madhya Pradesh Private University Regulatory Commission, challenging their appointment. The petitioner had raised allegations of misuse of post and public money.

The Division Bench of Acting Chief Justice Vivek Rusia and Justice Pradeep Mittal held, “The aforementioned petitions i.e. W.P. No.11341/2025, W.P. No.18974/2025 and W.P. No.24052/2025 were filed on 26.03.2025, 20.05.2025 and 25.06.2025, respectively. Before filing these writ petitions, the petitioner had already made a detailed complaint to the Lokayukta and thereafter filed these petitions. The petitioner submits that all the complaints have been disposed of. Therefore, once the Competent Authority has enquired into the matter and closed the same, then Public Interest Litigation is certainly not liable to be entertained.”

Petitioner appeared in person while Government Advocate S. S. Chouhan represented the Respondent.

Factual Background

The petitioner claimed that the future of more than 1 lakh students was at stake and the Court should direct the higher authorities, i.e. higher education department and other competent authority, to hold an impartial inquiry and submit the report at the earliest. As per the petitioner, the appointment of the Chairman was not in accordance with the law, and the authority given under the statute to the Chairman was being misused. The petitioner alleged that this was a case of organized, planned and gross irregularity related to corruption done by misusing government property and money. The petitioner thus sought a direction to the competent authority, Lokayukta, and CBI to conduct a fair investigation and submit the report as early as possible. The petitioner had filed the three petitions on such grounds.

Reasoning

Considering that the Competent Authority had closed the matters, the Bench held that the Public Interest Litigation was not liable to be entertained.

The Bench noted that the respondents were appointed in the year 2020 who had worked for the last 5 years, and now they were at the fag end of their careers. “Even otherwise, the term of respondent No.5 and others is over and vide notification dated 04.11.2025, new Chairman and Members have been appointed”, it noted.

“Since the petitioner has filed the petitions on behalf of one of the respondents i.e. Dr. Vishwas Chouhan who happens to be client in subsequent writ petitions, therefore, there is all possibility that all the information and facts mentioned in these Public Interest Litigations were collected from him which has been suppressed in para 4 of the Memo of the Writ Petition”, it added.

Thus, considering such facts and circumstances, the Bench dismissed all three petitions with the cost of Rs 25,000 each.

Cause Title: Anil Singh v. The State of Madhya Pradesh (Neutral Citation: 2026:MPHC-JBP:52560)

Appearance

Petitioner: In person

Respondent: Government Advocate S. S. Chouhan, Advocates Anvesh Shrivastava, Aman Pandey

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