PIL on Police University VC Dismissed With Rs 1 Lakh Costs

Undisclosed Litigation Sinks PIL on Police University VC Appointment: Rajasthan High Court Imposes Rs 1 Lakh Costs

Published: 3 November 2026 · NyayVidhan · 3 min read

A Division Bench of the Rajasthan High Court dismissed, with Rs 1,00,000 costs, a public interest litigation challenging Section 11(1) of the Sardar Patel University of Police, Security and Criminal Justice, Jodhpur Act, 2012 and the Vice-Chancellor's appointment. The petitioner had not disclosed his own litigation, as Rule 385-F of the High Court Rules requires, and the Court found the petition was filed to settle a personal score (paras 24-25, 32, 34). The validity of Section 11(1) was left open (para 33).

Key holdings

Disclosure under Rule 385-F(7) of the petitioner's own civil, revenue and criminal litigation is mandatory in a PIL (paras 22-23).

The right of any person to seek quo warranto does not dispense with the PIL disclosure rules when the writ is sought through a PIL (para 28).

Who instituted the undisclosed cases, or how serious they are, does not matter; the Rule requires their details (para 28).

A PIL filed to settle a personal score was dismissed with Rs 1,00,000 costs, without deciding the validity of Section 11(1) (paras 33-34).

Judgment digest by NyayVidhan: a summary of the court's judgment, not its text. The judgment itself is the authoritative version.

Brief Facts

The petitioner was an Assistant Professor at the university while respondent No. 6 served as its Vice-Chancellor from 2020 to 2023, and filed this PIL in 2024 after the Vice-Chancellor's reappointment (para 20). He challenged Section 11(1) of the 2012 Act, which he said lets the Chancellor appoint a Vice-Chancellor without the eligibility conditions of the UGC Regulations, 2018, and the advertisement of 12 December 2023, and sought the Vice-Chancellor's removal by a writ of quo warranto (paras 1-2, 5, 11-14). The respondents objected that the petition did not disclose the cases against the petitioner, as Rule 385-F requires (paras 3, 15-18). The petitioner replied that a quo warranto petition needed no such disclosure (para 10).

Court's Findings

The Court found that personal grievances against respondent No. 6 had been 'camouflaged' as a public interest litigation (para 20). The petitioner raised no objection to the Vice-Chancellor's qualifications while serving under him and approached the Court only in 2024, after proceedings had been initiated against him at the Vice-Chancellor's instance, although the appointment rules were unchanged between 2020 and 2024 (para 20). Rule 385-F(7) requires a PIL petitioner to disclose any civil, revenue or criminal litigation in which he is or has been involved, and that disclosure is mandatory (paras 22-23). His silence about the pending and decided cases listed in the reply was a 'material suppression of fact' (paras 24-25). Following Himmat Singh Gehlot and Sandeep Soni, it treated these disclosures as threshold tests of bona fides (paras 26-27). It accepted, as in Rajesh Awasthi, that anyone may seek quo warranto, but held that a quo warranto prayer made through a PIL must still meet the PIL rules, whoever filed the undisclosed cases (para 28). Citing Dr. B. Singh and Jaipur Shahar Hindu Vikas Samiti, it said PIL is no forum for personal vendettas, and the non-disclosure alone disentitled the petitioner (paras 29-32).

Legal Principle

A petitioner in a public interest litigation before the Rajasthan High Court must disclose all civil, revenue and criminal litigation in which he is or has been involved (Rule 385-F(7)). Suppressing it is an abuse of process that disentitles him at the threshold, even where the relief sought is a writ of quo warranto (paras 23, 25, 28, 32).

NyayVidhan's view · Practice note

Why It Matters

The judgment adds to the Rajasthan High Court's line of rulings that enforce the Rule 385-F disclosures strictly. In Ramniwas Daga, five PILs were dismissed with costs for concealing earlier petitions; here the undisclosed material was the petitioner's own litigation, and costs of Rs 1,00,000 followed (paras 24-25, 34). Petitioners and their counsel should list every civil, revenue and criminal matter, whoever started it, before seeking quo warranto through a PIL (para 28). The Court expressly left the validity of Section 11(1) open (para 33), so that question remains undecided. On the limits of quo warranto itself, see Sunil Samdaria.

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

Precedents Relied Upon

Rajesh Awasthi v. Nand Lal Jaiswal AIR 2013 SC 78
Distinguished Discussed at ¶ 6, 28
Supreme Court. Relied on by the petitioner for the proposition that any person may seek a writ of quo warranto without showing personal interest. The Bench did not dispute the proposition but held that a quo warranto prayer made through a public interest litigation must still satisfy the disclosure rules governing PILs (para 28).
Himmat Singh Gehlot v. State of Rajasthan D.B. Civil Writ Petition No. 24826/2025
Relied Upon Discussed at ¶ 26
Coordinate Bench of the Rajasthan High Court. Quoted for the view that Rule 385-F prescribes mandatory disclosures so that the Court can examine a PIL petitioner's bona fides, credibility and locus at the very threshold.
Sandeep Soni v. State of Rajasthan & Ors. D.B. Civil Writ Petition No. 2605/2026, decided on 13.4.2026
Relied Upon Discussed at ¶ 27
Coordinate Bench of the Rajasthan High Court. Quoted for holding that a PIL petitioner who does not make the Rule 385-F and 385-H disclosures, including his criminal antecedents, abuses the process of law and cannot be permitted to continue the litigation.

View all precedents (5)

Dr. B. Singh v. Union of India & Ors. 2004(3) SCC 363
Relied Upon Discussed at ¶ 30
Supreme Court. Quoted on public interest litigation as a weapon to be used with great care, not as a cover for private malice or personal vendetta, and on rejecting busybodies' petitions at the threshold, in appropriate cases with exemplary costs.
Jaipur Shahar Hindu Vikas Samiti v. State of Rajasthan and others (2014) 5 SCC 530
Relied Upon Discussed at ¶ 31
Supreme Court (three Judges). Quoted for the duty of courts to deal with misuse of public interest litigation with an iron hand and to discourage unjustified litigants at the initial stage.