The High Court of Telangana has reaffirmed that prolonged inaction by administrative authorities on pending revision petitions and representations under a statutory settlement scheme constitutes a violation of the fundamental principle of natural justice. This order provides critical clarity on the duty of timely adjudication, particularly where statutory remedies are pending and parties seek relief under newly introduced settlement frameworks.
Background & Facts
The Dispute
The petitioner, Sri R. Devender Reddy, holds a quarry lease for stone and metal over 2.00 hectares in Survey No. 221, Keesara Village, Medchal-Malkajgiri District. In 2024, the Assistant Director of Mines and Geology issued a demand notice under the Mines and Minerals (Development and Regulation) Act, 1957 and the Telangana State Minor Mineral Concession Rules, 1966, alleging non-payment of royalties and penalties. The petitioner challenged this notice through a revision petition, which remained undecided for months.
Procedural History
- 2024: Petitioner filed W.P. No. 4966 of 2024 challenging the demand notice.
- 12 December 2024: High Court directed the State to dispose of the revision petition by 10 February 2025.
- 12 March 2025: Government notified the One Time Settlement (OTS) Scheme, offering relief to parties with pending revision cases.
- 21 April 2025: Petitioner submitted a representation requesting a revised demand notice under the OTS Scheme.
- 16 February 2026: Petitioner approached the High Court seeking mandamus to compel disposal of both the revision and the representation.
Relief Sought
The petitioner sought a writ of mandamus directing the respondents to dispose of the pending revision petition and the representation dated 21 April 2025, arguing that continued inaction violated principles of natural justice and rendered statutory remedies illusory.
The Legal Issue
The central question was whether administrative inaction on a pending revision petition and a representation seeking relief under a statutory settlement scheme, after a court-directed timeline, amounts to a violation of principles of natural justice under Article 14 and Article 21 of the Constitution.
Arguments Presented
For the Petitioner
Smt. N. Shoba argued that the State’s failure to decide the revision petition despite a court order, and its silence on the representation filed under the OTS Scheme, amounted to procedural arbitrariness. She relied on State of U.P. v. Mohd. Noor to assert that delay in adjudication defeats the purpose of statutory remedies and violates the right to fair hearing. The petitioner had acted in good faith by availing the OTS Scheme, and the State’s inaction rendered the scheme ineffective.
For the Respondent
Sri K. Shantan Rao, Assistant Government Pleader, conceded that the representation remained pending but submitted that it would be disposed of expeditiously. He did not dispute the legal principle of timely adjudication but argued that no malafide intent existed and that the delay was administrative, not intentional.
The Court's Analysis
The Court examined the nature of the petitioner’s representation under the OTS Scheme and the State’s obligation under the Mines and Minerals Act to ensure procedural fairness. It noted that the Government had explicitly created the OTS Scheme to resolve pending disputes, thereby implying a duty to process applications within a reasonable timeframe.
"The State cannot create a scheme for settlement and then allow it to remain a dead letter by failing to act on representations made in good faith."
The Court emphasized that natural justice requires not only a hearing but also a timely decision. The earlier direction by the Court to dispose of the revision by 10 February 2025 had already established a binding timeline. The State’s failure to comply, coupled with the unaddressed representation, rendered the petitioner’s statutory rights ineffective.
The Court rejected the notion that administrative delay is harmless, holding that procedural fairness is not a technicality but a substantive right. The petitioner had no alternative remedy, and the delay had caused prejudice by prolonging uncertainty over the leasehold rights and financial liability.
The Verdict
The petitioner succeeded. The Court held that administrative inaction on pending statutory representations violates principles of natural justice and directed the Assistant Director to decide the representation dated 21 April 2025 within ten days, after affording the petitioner a hearing. No costs were imposed.
What This Means For Similar Cases
Timely Adjudication Is Non-Negotiable
- Practitioners must now treat statutory timelines and court-directed deadlines as binding obligations, not suggestions.
- Where a government scheme is introduced to resolve pending disputes, failure to act on representations under it can be challenged as arbitrary under Article 14.
- Delay beyond a reasonable period, even without malafide intent, can constitute a violation of natural justice.
OTS Schemes Create Procedural Rights
- Parties availing settlement schemes acquire a legitimate expectation of timely disposal.
- Representations filed under such schemes are not mere appeals but enforceable claims under administrative law.
- Authorities must record reasons for delay or rejection; silence is not an answer.
Mandamus Is Available for Procedural Failures
- Writ of mandamus is maintainable not only for refusal to act but also for unreasonable delay in acting.
- Courts will intervene when statutory remedies are rendered ineffective due to administrative apathy.
- Practitioners should cite this judgment when opposing adjournments or delays in quasi-judicial proceedings under mining, taxation, or licensing laws.
