2026 Supreme(Raj) 268
HIGH COURT OF JUDICATURE FOR RAJASTHAN, BENCH AT JAIPUR
SAMEER JAIN, J.
Daksh Education Trust (A Trust), Through Its Present President Tej Singh Rajawat, Son Of Shri Madan Singh Rajawat - Petitioner
Versus
State Of Rajasthan, Through The Secretary, Animal Husbandry And Live Stock Department – Respondent
S.B. Civil Writ Petition No. 5104 of 2019
Decided On : 19-05-2026
Important Points
Subject
Administrative Law - Natural Justice
Headnote
(B) Writ Jurisdiction - Mootness - When new policies and guidelines are formulated and a fresh application is submitted by the petitioner, previous disputes regarding earlier rejections are rendered of mere academic importance. (Paras 6, 7)
Facts of the case:
The petitioner challenged an order rejecting the grant of a No Objection Certificate (NOC), contending that the order was passed in a routine and cryptic manner despite a prior judicial direction to issue a reasoned and speaking order. It was alleged that the respondent adopted a discriminatory approach in granting NOCs to other institutions. Subsequently, the state formulated new guidelines in 2025, and the petitioner filed a fresh application under the new policy.
Findings of Court:
The court observed that the respondent admitted the previous order rejecting the NOC was not logical, rationale, or in compliance with judicial directions. However, in light of the new policy and the filing of a fresh application, the underlying dispute originating from the previous rejection became academic.
Issues: Whether the administrative failure to pass a reasoned order justified the current prayer and whether the petition survived the introduction of new policy guidelines.
Ratio Decidendi: State authorities must ensure that administrative decisions are specific and speaking to satisfy the requirements of natural justice. A challenge to an old administrative decision becomes academic when the petitioner seeks relief under a newly introduced policy via a fresh application.
Result: Writ petition disposed of with a direction to the competent authorities to adjudicate the fresh application in accordance with law and the governing policy within 60 days.
For the Petitioner: Mr. Saransh Saini with Mr. Vinod Kumar Sharma, Mr. Neeraj Kumar Pal, Ms. Aayushi Singh, Ms. Sanjana Choudhary.
For the Respondents: Mr. Abhishek Sharma for Mr. Manoj Sharma, AAG.
Order :
SAMEER JAIN, J.
1. Learned counsel for the petitioner submitted that the present is a second round of litigation. It is submitted that the erstwhile writ petition: S.B. Civil Writ Petition No. 14753/2012, was disposed of by this Court vide order dated 15.01.2013, with specific directions to the respondent-authorities to pass a reasoned and speaking order qua the issue of rejection of the No Objection Certificate (NOC).
2. It is submitted that despite explicit directions of the Court (Annexure-11), the respondents flouted the mandate and proceeded to pass the impugned order dated 15.03.2013 (Annexure-12) in routine and cryptic manner, arbitrarily rejecting the NOC qua the petitioner, under the garb of a purported policy decision. It is next submitted that the respondents adopted a discriminatory pick and choose mechanism, whereby NOCs have were already granted to umpteen of other colleges while wrongfully rejecting the petitioner’s claim.
3. At this juncture, learned counsel for the petitioner fairly concedes that pursuant to subsequent directions passed by this Court, the State Government formulated new policies and guidelines in the year 2025 for the grant of NOCs, under which the petitioner has already submitted an application, thus, the limited prayer advanced before this Court is qua the careless, arbitrary, and unfair administrative conduct of the State in its past decision-making process.
4. Per contra, learned counsel appearing on behalf of the respondent-State submits that the refusal to grant the NOC was a conscious policy decision. However, it is admitted that the order dated 15.03.2013 is not a logical and rationale order, as the same is ought to be detailed and well-reasoned, as in compliance with the judicial directions, as enumerated in the order dated 15.01.2013, passed in S.B. Civil Writ Petition No. 14753/2012. Qua the allegations of pick and choose method, it is submitted that the NOCs granted to other colleges were in compliance with specific judicial interventions and in compliance of the orders passed by the Court, as and when, under the different petitions.
5. Reliance in regard of the aforesaid is placed upon the orders passed by the Coordinate Bench of this Court at the Principal Seat, Jodhpur, in S.B. Civil Writ Petition No. 73/2026 titled Asian Institute of Veterinary Science v. State of Rajasthan & Ors. and S.B. Civil Writ Petition No. 6016/2026 titled Shivgyan Livestock Diploma Training Institute v. State of Rajasthan & Ors.
6. Learned counsel further relied upon the order dated 20.04.2026 passed by this Court in S.B. Civil Writ Petition No. 6914/2026 titled Rajasthan Public Pashudhan Mahavidhyalaya v. State of Rajasthan & Ors and submitted that since the petitioner has already applied afresh under the guidelines issued in the year 2025, the present lis pertaining to the year 2012 is rendered of mere academic importance. It is lastly submitted that the petitioner’s application will be considered by the respondents as expeditiously as possible.
7. Having heard the rival submissions and considering the facts and circumstances of the case, this Court observes that the underlying lis originating from the year 2012 is reduced to academic importance, in light of the new policy and the petitioner’s fresh application.
8. However, taking note of the admission by the respondents that the order dated 15.03.2013 was not in compliance with the judicial observations and directions, this Court is of the view that the State authorities are expected to exercise their administrative powers with utmost responsibility, ensuring that the orders passed thereto are specific, well-reasoned, and speaking in nature, in strict adherence to the principles of natural justice.
9. Considering the facts and circumstances, this Court deems it appropriate to dispose of the present writ petition with direction to the competent respondent-authorities to consider and adjudicate the petitioner’s fresh application filed under the new, stri