The Supreme Court dismissed the Special Leave Petition challenging the High Court’s rejection of a PIL alleging fraudulent revision of costs in the Palamuru-Ranga Reddy Lift Irrigation Scheme. The Court held that factual adjudication cannot be pursued under Article 226 and upheld the High Court’s discretion in refusing a CBI probe, citing prior findings by the Central Vigilance Commission and constructive res judicata. The ruling reaffirmed judicial restraint in interfering with discretionary orders absent jurisdictional errors.
Facts Of The Case:
The petitioner, Nagam Janardhan Reddy, a former MLA and Minister in Andhra Pradesh, filed a Public Interest Litigation (PIL) before the High Court of Telangana and Andhra Pradesh, alleging fraudulent revision of cost estimates for the Palamuru-Ranga Reddy Lift Irrigation Scheme (PRRLIS). The original estimate for Electro-Mechanical (E&M) equipment, prepared by the Engineering Staff College of India, was Rs. 5,960.79 crores, but the respondents (State of Telangana and others) revised it to Rs. 8,386.86 crores, causing an alleged loss of Rs. 2,426.07 crores to the public exchequer. The petitioner sought a writ of mandamus to declare the revision illegal and arbitrary, along with a CBI investigation into the matter.
The High Court dismissed the PIL, prompting the petitioner to approach the Supreme Court via a Special Leave Petition (SLP). The respondents argued that the petition was barred by constructive res judicata, as similar PILs had been filed earlier and dismissed. They also cited a Central Vigilance Commission (CVC) report, which found no substance in the allegations. The Supreme Court upheld the High Court’s decision, ruling that factual disputes cannot be adjudicated in writ proceedings under Article 226 and that the High Court was justified in refusing a CBI probe. The Court noted the petitioner’s history of litigating the same issue and emphasized the CVC’s findings in dismissing the SLP.
Procedural History:
The case originated with a Public Interest Litigation (PIL) filed by Nagam Janardhan Reddy before the High Court of Judicature at Hyderabad, challenging the revision of cost estimates for the Palamuru-Ranga Reddy Lift Irrigation Scheme (PRRLIS). The High Court dismissed the PIL on December 3, 2018, prompting the petitioner to file a Special Leave Petition (SLP No. 7005 of 2019) before the Supreme Court. During the proceedings, the Supreme Court initially raised preliminary objections regarding the maintainability of the SLP, noting issues of constructive res judicata and suppression of material facts. The Court also considered an earlier order dated August 25, 2022, which highlighted these objections. After hearing arguments from both sides, the Supreme Court dismissed the SLP on May 21, 2025, upholding the High Court’s decision and declining to interfere with its discretionary refusal to order a CBI probe. The Court referenced the Central Vigilance Commission’s findings and the petitioner’s repeated litigation on the same issue, concluding that no further judicial intervention was warranted.
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Court Observation:
The Supreme Court made several key observations while dismissing the Special Leave Petition. It noted that the petitioner’s challenge primarily involved factual disputes regarding cost revisions in the irrigation project, which fell outside the scope of writ jurisdiction under Article 226 of the Constitution. The Court emphasized that the High Court had appropriately exercised its discretion in refusing to order a CBI investigation, particularly since the Central Vigilance Commission had already examined the allegations and found them unsubstantiated.
The bench observed that the petitioner had previously filed multiple PILs on similar grounds, raising concerns about constructive res judicata and the belated timing of the challenge. The Court also pointed out that significant portions of the project had already been completed, making judicial intervention at this stage impractical. Ultimately, the Supreme Court declined to interfere with the High Court’s decision, reinforcing the principle that discretionary orders should not be overturned unless they suffer from jurisdictional errors or manifest injustice. The ruling underscored judicial restraint in matters requiring factual adjudication and deference to specialized investigative bodies like the CVC.
Final Decision & Judgement:
The Supreme Court, in its final judgment dated May 21, 2025, dismissed the Special Leave Petition and upheld the High Court’s decision to reject the PIL. The bench comprising Justices B.V. Nagarathna and Satish Chandra Sharma ruled that the petitioner’s allegations regarding fraudulent cost revisions in the Palamuru-Ranga Reddy Lift Irrigation Scheme involved factual disputes unsuitable for writ jurisdiction under Article 226. The Court affirmed the High Court’s discretionary refusal to order a CBI probe, particularly noting the Central Vigilance Commission’s prior finding that the allegations were unsubstantiated. The judgment emphasized that the petitioner’s repeated litigation on similar grounds raised issues of constructive res judicata, and that belated challenges to substantially completed projects would serve no public purpose. The Court disposed of all pending applications, including intervention pleas, while reaffirming the judiciary’s limited role in second-guessing administrative decisions absent clear illegality or mala fides. This decision reinforced constitutional boundaries on PIL jurisdiction and judicial restraint in matters involving complex technical and financial assessments by executive authorities.
Case Details:
Case Title: Nagam Janardhan Reddy vs. State of Telangana & Others Citation: 2025 INSC 798 Case Number: Special Leave Petition (Civil) No. 7005 of 2019 Date of Judgment: May 21, 2025 Bench: Justice B.V. Nagarathna & Justice Satish Chandra Sharma
Download The Judgement Here