Dismissal of PIL Regarding Palamuru Ranga Reddy Lift Irrigation Scheme (PRRLIS) Estimates.


21 May 2025 Public Interest Litigation >> Constitution & Law Procedure  

The Supreme Court has dismissed a Special Leave Petition (SLP) in Nagam Janardhan Reddy v/s State of Telangana & Others, filed by a former Member of Legislative Assembly (MLA) challenging the High Court's dismissal of his Public Interest Litigation (PIL) concerning alleged fraudulent revision of estimates for the Electro Mechanical (E&M) Equipments in the Palamuru Ranga Reddy Lift Irrigation Scheme (PRRLIS).

The petitioner, a six-time MLA and former minister, had filed PIL No. 338 of 2017 before the High Court of Judicature at Hyderabad. He sought a declaration that the revision of the E&M equipment value for PRRLIS packages 1, 5, 8, and 16 from Rs.5960.79 crores (estimated by the Engineering Staff College of India) to Rs.8386.86 crores (by the Advisor and Departmental Committee) was fraudulent, causing a loss of Rs.2426.07 crores to the public exchequer. He also sought an investigation by the Central Bureau of Investigation (CBI) into these actions.

 
 

The High Court dismissed the PIL on December 3, 2018, leading to the current SLP.

During the Supreme Court's proceedings, the petitioner's counsel argued that the High Court should not have summarily dismissed the petition. They contended that the High Court should have either referred the matter to the CBI for investigation or devised a procedure to uncover the alleged fraud.

In response, the counsel for the project proponent and the State argued that the High Court's dismissal was justified. They raised preliminary objections regarding the maintainability of the PIL, citing that the petitioner had filed similar PILs (Nos. 28/2016, 179/2016, and 338/2017) concerning the same project, which had already been disposed of. They also highlighted an order dated August 25, 2022, from the Supreme Court noting that the PIL was potentially barred by constructive res judicata and involved suppression of material facts.

Furthermore, it was brought to the Court's attention that the Central Vigilance Commission (CVC) had already examined a complaint from the same petitioner regarding PRRLIS packages 5 and 8. In an Office Memorandum dated September 12, 2017, the CVC concluded that the complaint was "false" and "not at all substantiated," deciding to close the matter.

The Supreme Court affirmed the High Court's decision, noting that the first prayer seeking a declaration of fraud involved factual adjudication, which is not typically undertaken in a writ petition under Article 226 of the Constitution of India. Regarding the second prayer for a CBI investigation, the Court found that the High Court was justified in not exercising its discretion to refer the matter to the CBI. The Supreme Court stated that it could not "sit in judgment over the non-exercise of discretion" by the High Court in this regard.

The Court also acknowledged the petitioner's continuous pursuit of the matter and the CVC's finding that his complaint was unsubstantiated. Consequently, the Supreme Court found no reason to interfere with the impugned order and dismissed the Special Leave Petition.