A writ petition styled as Public Interest Litigation is non-maintainable if it is rooted in personal interests rather than genuine public concerns.

Per Ramesh Sinha , Chief Justice

05.08 .2025

1. Heard Mr. Jai Prakash Shukla, learned counsel for the petitioner as well as Mr. Sangharsh Pandey, learned Government Advocate, appearing on behalf of the State/respondents.

2. The present petition has been filed by the petitioner with the following relief(s):-

“10.1 That the Hon'ble Court may kindly be pleased to issue writ in the nature of mandamus/certiorari/prohibition thereby to declare Rule 13(C)(1) of Chhattisgarh Medical, Dental, and Physical Treatment (Physiotherapy) Under-Graduate Admission Rules 2025 as notified in official Gazette of Chhattisgarh with No. RULE- 503/30/2025/MED Dated 16/07/2025 and the complete Admission Rules 2025 as ultra-

vires.

10.2 Hon'ble Court may kindly be pleased to issue writ in the nature of mandamus/certiorari/prohibition thereby to quash impugned Rule 13(C)(1) of Chhattisgarh Medical, Dental, and Physical Treatment (Physiotherapy) Graduate Admission Rules 2025 as notified in official Gazette of Chhattisgarh with No. RULE- 503/30/2025/MED Dated 16/07/2025 and the complete Admission Rules, 2025 being illegal, unconstitutional and ultra-vires.

10.3 That, the Hon'ble Court may kindly be pleased direct the respondents to frame suitable legislation to prevent mis-utilization of such quota or any malpractice referable to NRI quota seats, as directed by The Hon'ble Supreme Court in P.A. Inamdar Supra and so long as the State does not do it, constitute Committee pursuant to case of Islamic Academy's direction to regulate such quota.

10.4 Any other relief as deemed fit by this Hon'ble Court may also be granted in favour of the petitioner.”

3. The present petition in the style of public interest litigation has been filed by the petitioner seeking to declare the Rule 13(C)(1) of Chhattisgarh Medical, Dental, and Physical Treatment (Physiotherapy) Under-Graduate Admission Rules 2025 as notified in official Gazette of Chhattisgarh with No. RULE- 503/30/2025/MED dated 16/07/2025 and the complete Admission Rules 2025 as ultra-vires and to quash the same and to direct the respondents to frame suitable legislation to prevent mis-utilization of such quota or any malpractice referable to NRI quota seats.

4. Perusal of the pleadings, particularly Clause (II) of the “Subject Matter in Brief,” reveals that the petitioner has described himself as a social activist and a resident of Raipur (C.G.), associated with various social and cultural associations. It is further stated that children from his family and among his relatives are appearing for the NEET examinations. On this basis, the petitioner claims to be a bona fide victim/sufferer and has approached this Court not only in his ‘personal capacity’, but also in a representative capacity, seeking redressal of what he alleges to be a violation of fundamental rights.

5. The said averment, on its plain reading, clearly reflects that the petitioner has a direct and personal interest in the outcome of the present proceedings, as members of his own family and relatives are stakeholders in the NEET examination process. Therefore, although the petition is styled as being in ‘public interest’, the petitioner’s submissions disclose a ‘personal stake’, thereby diluting the element of objectivity and public character expected in a genuine Public Interest Litigation (PIL). The presence of such personal interest runs contrary to the well-settled principles governing maintainability of PILs, as laid down by the Hon’ble Supreme Court in a catena of decisions.

6. Be that as it may, we are not considering whether the pleadings made by the petitioner are correct or not, but the issue for consideration of this Court is whether the writ petition filed in the style of 'Public Interest Litigation' is maintainable or not when the pleadings prima facie show the 'private inter