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Patna High Court

BiharversusAnisha Raj

Decided
Disposal
DISPOSED

Holding

Since the petitioner’s grievance has been resolved and no relief remains to be granted, the Letters Patent Appeal is disposed.

Summary

The petitioners, led by Anisha Raj, sought a court order directing the State Government to transfer her to the fourth year of the Patna Dental College and for the Dr. B.R. Ambedkar Institute of Dental Sciences to issue a transfer certificate. The Single Judge ordered the transfer within four weeks and the issuance of documents within ten days. On appeal, the respondents argued that the petitioner had already secured admission in a private dental college, rendering the grievance moot. The Advocate General concurred that the matter was settled. The High Court, after noting that no issue remained for adjudication, disposed of the Letters Patent Appeal.

Issues considered

  • What is the appropriate course of action when the relief sought in a writ petition has already been satisfied by the petitioner’s voluntary actions?
  • Can a Letters Patent Appeal be entertained when the underlying grievance no longer exists?

Subjects

  • transfer of student
  • dental education
  • letters patent appeal
  • settlement of dispute
  • jurisdiction
  • higher education
  • administrative law

Judgment

          IN THE HIGH COURT OF JUDICATURE AT PATNA
                        Letters Patent Appeal No.544 of 2025
                                          In
                    Civil Writ Jurisdiction Case No.17291 of 2024
     ======================================================
1.    The State of Bihar through the Chief Secretary, Department of Health and
      Family Welfare, Government of Bihar, Vikas Bhawan, New Secretariat,
      Patna, Pin- 800015.
2.   The Additional Chief Secretary, Department of Health and Family Welfare,
     Government of Bihar, Vikas Bhawan, New Secretariat, Patna, Pin- 800015.

                                                          ... ... Appellant/s
                                   Versus
1.   Anisha Raj Daughter of Anil Kumar Resident of Village- Bochahi, P.S.-
     Muffasil, District- Munger.
2.   The Union of India, through the Secretary, Ministry of Health and Family
     Welfare, Government of India, Nirman Bhawan, Maulana Azad Road, New
     Delhi, Delhi- 110011.
3.   The Secretary, Ministry of Health and Family Welfare, Government of India,
     Nirman Bhawan, Maulana Azad Road, New Delhi, Delhi- 110011.
4.   The Dental Council of India, through its President, National Dental
     Commission Building, Plot no.- 14, Sector-9, R.K. Puram, New Delhi, Pin-
     110022.
5.   The President, Dental Council of India, National Dental Commission
     Building, Plot no.- 14, Sector-9, R.K. Puram, New Delhi, Pin- 110022.
6.   The Magadh University, through the Vice Chancellor, Bodh Gaya, Gaya,
     Bihar, Pin- 824234.
7.   The Controller of Examinations, Magadh University, Bodh Gaya, Gaya,
     Bihar, Pin- 824234.
8.   The Dr. B.R. Ambedkar Institute of Dental Sciences and Hospital, through
     its Principal, Hari Om Nagar, New Bailey Road, Patna, Bihar, Pin- 801503.

                                               ... ... Respondent/s
     ======================================================
     Appearance :
     For the Appellant/s    :     Mr. S.D. Sanjay, Advocate General
                                  Mr. Rahul Kumar, A.C. to A.G.
     For the Respondent/s   :     Mr. Additional Solicitor General
     For the D.C.I.         :     Mr. Mohit Agarwal, Advocate
     For the M.U.           :     Mr. Siddhartha Prasad, Advocate
     For the U.O.I.         :     Mr. Brajesh Kumar Pandey, C.G.C.
     ======================================================
     CORAM: HONOURABLE THE CHIEF JUSTICE
             and
             HONOURABLE JUSTICE SMT. SONI SHRIVASTAVA

     ORAL JUDGMENT
Patna High Court L.P.A No.544 of 2025 dt.29-06-2026
                                              2/3




       (Per: HONOURABLE THE CHIEF JUSTICE)

       Date : 29-06-2026

                    The instant Letters Patent Appeal impugns the

         order dated 08.04.2025 passed by the learned Single Judge

         in C.W.J.C. No. 17291 of 2024, whereby the learned Single

         Judge directed the State Government to take necessary

         steps to transfer the petitioner to the 4th year in Patna

         Dental College, Patna within a period of four weeks from

         the date of receipt/production of the order. Further, Dr. B.R.

         Ambedkar Institute of Dental Sciences and Hospital, Patna

         was also directed to issue the transfer certificate and other

         necessary documents to the petitioner within 10 days from

         the date of receipt/production of a copy of the impugned

         order. Other consequential directions were also issued,

         which, to avoid prolixity, are not being reproduced herein.

                    2. Learned counsel appearing for the respondents

         submits that the Respondent has now been accommodated

         in a private Dental College and, therefore has further no

         grievance to be considered by this Court.

                    3. Learned Advocate General submits that, since

         the matter has been settled, it may be disposed of

         accordingly.

                    4. Having considered the submissions advanced on

         behalf      of    the     parties,     nothing    further    survives   for

         adjudication in the present matter.

                    5.    The     present Letters         Patent     Appeal   stands
             Patna High Court L.P.A No.544 of 2025 dt.29-06-2026
                                                          3/3




                      disposed of, accordingly.




                                            (Meenakshi Madan Rai, CJ)


                                                  (Soni Shrivastava, J)
Neha/-
AFR/NAFR
CAV DATE
Uploading Date          03.07.2026
Transmission Date


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