Madras High Court Dismisses Writ Petition as Infructuous after Prison Authorities Comply with Request for Prisoner Transfer. Writ of Mandamus Sought for Shifting of Prisoner from Central Prison, Madurai to Central Prison, Palayamkottai, Which Was Already Granted by the Authorities, Rendering the Petition Moot.

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

The petitioner, Prithima, filed a writ petition under Article 226 of the Constitution of India seeking a writ of mandamus directing the prison authorities to transfer her husband, Johnpaul @ Balan (PID 518593), from Central Prison, Madurai to Central Prison, Palayamkottai. The petitioner had earlier submitted a representation dated 08.08.2024 to the Inspector General of Prisons and the Deputy Inspector General of Prisons, Madurai Range, but no action was taken, prompting her to approach the Madurai Bench of the Madras High Court. The respondents in the case were the Inspector General of Prisons, Chennai; the Deputy Inspector General of Prisons, Madurai Range; the Jail Superintendent, Central Prison, Madurai; and the Jail Superintendent, Central Prison, Palayamkottai. When the matter was taken up for hearing on 10.03.2025, the Additional Public Prosecutor appearing for the respondents submitted that the authorities had acceded to the petitioner’s request by an order dated 16.02.2025. The court noted that in view of this compliance, nothing survived for further adjudication in the writ petition. Accordingly, the writ petition was dismissed as infructuous. No legal principles or issues were decided; the court simply recorded the respondents’ statement and disposed of the case. The case highlights the procedural aspect of a writ of mandamus becoming infructuous when the relief sought is granted during the pendency of the proceedings.

Headnote

A) Writ of Mandamus - Prisoner Transfer - Article 226, Constitution of India - Petitioner sought transfer of her husband from Central Prison, Madurai to Central Prison, Palayamkottai based on representation dated 08.08.2024 - Respondents stated that the request had been acceded to by order dated 16.02.2025 - Held, writ petition dismissed as infructuous (Paras 3-4).

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Issue of Consideration

W.P(MD)No.3073 of 2025

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Final Decision

Writ Petition dismissed as infructuous.

Case Details

2025 LawText (MAD) (03) 225

W.P(MD)No.3073 of 2025

2025-03-10

Dr. Justice G. Jayachandran, Justice R. Poornima

2025:MHC:696

Mr. R. Venkateswaran, Mr. E. Antony Sahaya Prabahar

Prithima

1. The Inspector General of Prisons, 2. The Deputy Inspector General of Prisons, Madurai Range, 3. The Jail Superintendent, Central Prison, Madurai, 4. The Jail Superintendent, Central Prison, Palayamkottai

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Nature of Litigation

Writ petition under Article 226 of the Constitution seeking a writ of mandamus for transfer of a prisoner.

Remedy Sought

Petitioner (wife of prisoner) sought a direction to transfer her husband from Central Prison, Madurai to Central Prison, Palayamkottai.

Filing Reason

The petitioner's representation dated 8.8.2024 for transfer of her husband had not been acted upon, leading to the filing of the writ petition.

Issues

Whether the writ petition should be allowed when the relief sought has already been granted by the authorities, rendering it infructuous.

Submissions/Arguments

Petitioner sought transfer of her husband based on representation dated 08.08.2024. Respondents submitted that the request had been acceded to by order dated 16.02.2025, making the petition infructuous.

Judgment Excerpts

the request of the Writ Petitioner to transfer her husband John Paul @ Balan from Central Prison, Madurai to Central Prison Palayamkottai, has been acceded to by the authorities by order, dated 16.02.2025. nothing survives for further adjudication in this Writ Petition. Hence this Writ Petition is dismissed as infructuous.

Procedural History

The petitioner filed a representation on 8.8.2024 for transfer of her husband. Upon no response, she filed the writ petition. During the hearing on 10.03.2025, the respondents informed the court that the transfer had been ordered on 16.02.2025. The court then dismissed the petition as infructuous.

Acts & Sections

  • Constitution of India: Article 226
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