The Madras High Court has affirmed that prolonged inaction on statutory appeals by revenue authorities violates the foundational principle of natural justice, empowering courts to issue mandamus compelling timely disposal. This ruling provides critical relief to litigants caught in bureaucratic inertia, reinforcing the judiciary’s role as a guardian of procedural fairness.
Background & Facts
The Dispute
The petitioner, Dr. Sudhir Raja Ravindran, challenged the undue delay in the disposal of his statutory appeal filed on 06.11.2025 before the Revenue Divisional Officer (South), concerning property disputes at Door No. 132, Velacherry Main Road, Saidapet, Chennai. The appeal, filed under the Tamil Nadu Land Revenue Code, remained pending for over two months without any indication of progress, despite statutory timelines for adjudication.
Procedural History
- 06.11.2025: Petitioner filed statutory appeal before the 1st respondent (Revenue Divisional Officer)
- December 2025 - January 2026: No hearing scheduled, no order issued, no communication provided
- January 2026: Writ petition filed under Article 226 of the Constitution seeking direction for disposal
- 22.01.2026: Court heard arguments and issued order
Relief Sought
The petitioner sought a writ of mandamus directing the Revenue Divisional Officer to dispose of the pending appeal within a fixed timeframe, asserting that the delay amounted to a denial of the right to a fair and timely hearing.
The Legal Issue
The central question was whether a writ of mandamus under Article 226 can be issued to compel a statutory authority to dispose of a pending appeal within a reasonable time, where no valid reason for delay is shown and the delay infringes upon the principle of natural justice.
Arguments Presented
For the Petitioner
Mr. L. Dhamodharan, counsel for the petitioner, relied on State of Punjab v. Baldev Singh and K. S. Puttaswamy v. Union of India to argue that unreasonable delay in adjudicating statutory appeals violates the right to effective remedy under Article 21 and the doctrine of natural justice. He emphasized that statutory appeals are not mere formalities but substantive rights, and their indefinite pendency renders them meaningless.
For the Respondent
Mr. S. Arumugam, Government Advocate, accepted notice but did not contest the core contention. He acknowledged the delay and stated that the appeal was under consideration, but offered no specific timeline or justification for the lapse. The State did not dispute the legal proposition that delay in adjudication can amount to a violation of procedural fairness.
The Court's Analysis
The Court examined the nature of statutory appeals under the Tamil Nadu Land Revenue Code and observed that such appeals are not discretionary but mandatory, designed to provide an internal redressal mechanism. The Court held that while it would not interfere with the merits of the appeal, it could not permit indefinite delay in its adjudication.
"The right to a fair hearing includes the right to a hearing within a reasonable time. A statutory appeal that remains pending without reason or timeline is a denial of justice, not merely a delay in its delivery."
The Court distinguished this from cases where delay arises from complex factual or legal issues, noting that here, no such complexity was alleged or demonstrated. The absence of any communication or procedural activity for over two months constituted a breach of natural justice. The Court further cited S.P. Gupta v. Union of India to affirm that judicial review extends to administrative inaction that undermines statutory rights.
The Court rejected the notion that mandamus cannot be issued to compel action in pending matters, holding that where a legal duty exists and is unperformed, the remedy is available.
The Verdict
The petitioner succeeded. The Court held that natural justice requires timely adjudication of statutory appeals, and directed the Revenue Divisional Officer to dispose of the appeal within twelve weeks from receipt of the order. The Court explicitly clarified that this direction does not prejudge the merits of the appeal.
What This Means For Similar Cases
Timely Disposal Is a Legal Duty
- Practitioners may now file writ petitions under Article 226 where statutory appeals remain pending beyond 60-90 days without justification
- Courts will treat unreasonable delay as a violation of natural justice, not merely administrative inefficiency
- No need to await final order - delay itself is actionable
Mandamus Is Not Limited to Refusals
- Mandamus can compel action even when no explicit refusal has been issued
- The duty to decide is inherent in statutory appeal mechanisms
- Authorities must now maintain internal timelines and provide status updates to avoid judicial intervention
Procedural Fairness Trumps Technicalities
- Courts will not allow procedural technicalities to shield inaction
- Petitioners need not prove malice or mala fide - only unreasonable delay and lack of due process
- This principle applies across revenue, tax, land, and service appellate forums
