Madurai Bench of Madras High Court Closes Writ Petition Against Teachers Recruitment Board Due to Issuance of Addendum Satisfying Petitioner's Grievance. Addendum to Notification Allowed Candidates to Appear for Assistant Professor Examination Subject to Passing TNSET, Rendering Mandamus Prayer Infructuous.

High Court: Madras High Court Bench: Madurai
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Case Note & Summary

The petitioner filed a writ petition under Article 226 of the Constitution of India seeking a mandamus directing the Teachers Recruitment Board (third respondent) to issue an addendum to Notification No.1 of 2025 dated 24.01.2025, to enable her to apply for the post of Assistant Professor in Government Law Colleges and participate in the selection process. The notification apparently required candidates to have passed the TNSET 2024 examination, and the petitioner sought an addendum to address this condition. During the course of hearing, the learned Standing Counsel for the Teachers Recruitment Board placed before the court a copy of an addendum dated 21.02.2025, which stated that candidates would be allowed to appear for the written examination for the posts of Associate Professor, Assistant Professor, and Assistant Professor (Pre-Law) only if they passed the TNSET 2024 examination. The court, upon perusal of the addendum, formed the considered view that no further adjudication was required in the writ petition. Consequently, the writ petition was closed without any order as to costs, and the connected miscellaneous petitions were also closed. The legal issue for consideration was whether the petition required adjudication after the issuance of the addendum. The court found that the grievance of the petitioner stood resolved by the addendum, and thus the petition became infructuous. The ratio decidendi is that when the relief sought in a writ petition is rendered unnecessary by a subsequent action of the respondent, the court may close the petition without a detailed adjudication on merits.

Headnote

A) Service Law - Recruitment - Closure of writ petition upon satisfaction of grievance - Not mentioned - The petitioner sought a mandamus directing the Teachers Recruitment Board to issue an addendum to Notification No.1 of 2025 for the post of Assistant Professor; during hearing, the Board produced an addendum dated 21.02.2025 which allowed candidates to appear if they passed TNSET 2024, thereby resolving the issue; Held that no further adjudication was required and the petition was closed (Paras 2-3).

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Issue of Consideration

Whether the writ petition should be adjudicated or closed in light of the addendum issued by the Teachers Recruitment Board to Notification No.1 of 2025.

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Final Decision

Writ petition closed as no further adjudication required; no order as to costs; connected miscellaneous petitions closed.

Law Points

  • Legal points not extracted
  • Writ of Mandamus
  • issuance of addendum
  • closure of petition
  • infructuous relief
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Case Details

2025 LawText (MAD) (02) 289

W.P.(MD)No.4360 of 2025

2025-02-24

Battu Devanand

Citation not available

Mr.Meenakshi Rama Prabhu for petitioner; Mr.M.Siddharthan, Additional Government Pleader for respondents 1,2 &4; Mr.V.R.Shanmuganathan, Standing Counsel for respondent No.3

C.Ishwarya

The Secretary, Higher Education Department; The Secretary, Law Department; The Chairperson, Teachers Recruitment Board; The Director of Legal Education

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Nature of Litigation

Writ petition under Article 226 seeking a writ of mandamus against the Teachers Recruitment Board to issue an addendum to a recruitment notification.

Remedy Sought

Petitioner sought direction to third respondent to issue addendum to Notification No.1 of 2025 to enable her to apply for the post of Assistant Professor and participate in the selection process.

Filing Reason

The notification required candidates to have passed TNSET 2024, and the petitioner sought an addendum to facilitate her application.

Previous Decisions

Previous decisions not referenced

Issues

Whether the writ petition should be adjudicated or closed in light of the addendum issued by the Teachers Recruitment Board.

Submissions/Arguments

Petitioner sought a mandamus to direct issuance of an addendum; during hearing, the learned Standing Counsel for the Teacher Recruitment Board produced a copy of addendum dated 21.02.2025 stating that candidates would be allowed to appear if they pass TNSET 2024, thereby resolving the matter.

Ratio Decidendi

When the relief sought in a writ petition is satisfied by subsequent action of the respondent, the court may close the petition without further adjudication.

Judgment Excerpts

On perusal of the addendum dated 21.02.2025, issued by the Teachers Recruitment Board, in my considered view, no further adjudication is required in the present writ petition. Accordingly, this Writ Petition stands closed. There shall be no order as to costs.

Procedural History

Petitioner filed writ petition seeking mandamus; matter heard; during hearing, respondents produced addendum dated 21.02.2025; court found grievance resolved and closed the petition.

Acts & Sections

  • Constitution of India: Article 226
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