Lalit Gehlot SLP Dismissed: Raj HC Ends JNVU Special Appeals

Once Supreme Court Dismissed Lalit Gehlot SLP, Nothing Survived in JNVU's Special Appeals: Rajasthan High Court

Published: 30 October 2026 · NyayVidhan

The Rajasthan High Court at Jodhpur dismissed Jai Narain Vyas University's special appeal against a Single Judge's order in the respondent's favour, holding that nothing survived in it (para 9). A Division Bench had kept that order in abeyance only because the Supreme Court had stayed Lalit Gehlot, the decision on which it rested (para 8). The Supreme Court dismissed the University's special leave petition in Lalit Gehlot on 20 August 2026 (paras 6, 9). Twenty-five connected appeals were dismissed in the same terms by a separate order.

Key holdings

The Division Bench's interim order of 18 November 2024 kept the Single Judge's order in abeyance only because the Supreme Court had stayed Lalit Gehlot (paras 8-9).

The University could not dispute that its special leave petition in Lalit Gehlot was dismissed on 20 August 2026 (para 6).

With that petition dismissed, nothing survived in the special appeal, and it was dismissed (para 9).

All pending applications, including the stay application, were disposed of (para 10).

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Brief Facts

Jai Narain Vyas University and its Registrar appealed against a Single Judge's order allowing the respondent's writ petition on the basis of Lalit Gehlot & Ors. v. JNVU (S.B. Civil Writ Petition No. 5666/2022, decided on 26 April 2023) (paras 1, 8). The Supreme Court stayed Lalit Gehlot on 22 January 2024, and on 18 November 2024 a Division Bench kept the impugned orders in abeyance (paras 2, 8). By IA No. 1/2026 the respondent sought early disposal, as the Supreme Court had dismissed the University's Special Leave to Appeal No. 1745/2024 in Lalit Gehlot on 20 August 2026 (para 1). He also pointed to the dismissal of the University's appeal against Santosh Kumar on 16 September 2026 (paras 4-5).

Court's Findings

The University opposed the application but could not dispute that its special leave petition in Lalit Gehlot had been dismissed on 20 August 2026 (para 6). The interim order of 18 November 2024, set out in full, had found Lalit Gehlot to be the sole basis on which the Single Judge allowed the writ petition, and, because the Supreme Court had stayed it on 22 January 2024, kept the impugned orders in abeyance awaiting the Supreme Court's further order (para 8). The same order recorded the writ petitioners' plea that earlier favourable orders for similarly situated employees seeking regularisation, in JNVU v. Bhanwar Singh and JNVU v. Mukesh Sharma, kept their case alive despite the stay (para 8). Reading the interim order, the Court held that the University's protection rested on the Supreme Court's interim order of 22 January 2024 in the University's own special leave petition, and that the appeal's hearing had awaited that petition (para 9). With the petition dismissed on 20 August 2026, nothing survived in the appeal (para 9). The order does not examine the merits of the writ petition, or the Santosh Kumar and Mukesh Sharma decisions put forward for the respondent (paras 4-5, 9).

Legal Principle

Where an intra-court appeal is kept pending, and the Single Judge's order held in abeyance, only because the Supreme Court has stayed the decision on which that order rests, the Supreme Court's later dismissal of the special leave petition against that decision leaves nothing to decide in the appeal, which is dismissed (paras 8-9).

NyayVidhan's view · Practice note

Why It Matters

For the University and the writ petitioners who won before the Single Judge, this order ends a long wait. The special appeals had been held up, with the Single Judge's orders in abeyance, only because the Supreme Court had stayed Lalit Gehlot (para 8). Once the University's special leave petition was dismissed on 20 August 2026, the Division Bench found nothing left to decide (para 9), and the stay application went with the appeal (para 10). It also shows a practical route: where an appeal awaits the Supreme Court's decision in a lead case, an application for early disposal pointing to the final outcome, as IA No. 1/2026 did, can bring the appeal to an end (paras 1, 9).

Editorial comment by the NyayVidhan Editorial Desk. It is not part of the Court's judgment and is not legal advice.

Precedents Relied Upon

Lalit Gehlot & Ors. v. Jai Narain Vyas University, Jodhpur S.B. Civil Writ Petition No. 5666/2022, decided on 26.4.2023
Relied Upon Discussed at ¶ 1, 2, 8, 9
Single Bench decision on which the Single Judge's order in the respondent's favour rested; the Division Bench's interim order of 18.11.2024 found it to be the sole basis for allowing the writ petition and, as the Supreme Court had stayed it, kept the impugned orders in abeyance (paras 1, 2, 8). After the Supreme Court dismissed the University's special leave petition against it, the Court held that nothing survived in the appeal (para 9).
Jai Narain Vyas University & Anr. v. Lalit Gehlot Special Leave to Appeal No. 1745/2024 (batch headed by SLP No. 1258/2024), Supreme Court, interim order dated 22.01.2024 and order dated 20.08.2026
Relied Upon Discussed at ¶ 1, 2, 6, 9
The Supreme Court stayed Lalit Gehlot on 22.01.2024, the basis of the Division Bench's interim order, and dismissed the University's special leave petition on 20.08.2026, which the University could not dispute (paras 1, 2, 6). On that dismissal the Court held that nothing survived in the appeal and dismissed it (para 9).
Jai Narain Vyas University, Jodhpur & Anr. v. Santosh Kumar DBSAW No. 1700/2025, decided on 16.9.2026
Referred To Discussed at ¶ 1, 4, 5
Cited for the respondent: a Co-ordinate Bench dismissed the University's appeal, holding the case not distinguishable from Mukesh Sharma, and the Supreme Court is said to have relied on it in rejecting the Lalit Gehlot SLP (paras 1, 4, 5). The Court's own reasoning does not refer to it (para 9).

View all precedents (4)

JNVU, Jodhpur & Anr. v. Mukesh Sharma Civil Appeal No. 2096-2198/2022, decided on 28.3.2022
Referred To Discussed at ¶ 4
Cited for the respondent as a controversy that attained finality up to the Supreme Court, and followed in Santosh Kumar (para 4); also named in the writ petitioners' plea recorded in the quoted interim order (para 8). The Court's own reasoning does not refer to it (para 9).