Anil Lahre Vs State of Chhattisgarh — Writ and Judicial Review | Chhattisgarh HC (2026)

Anil Lahre Vs State of Chhattisgarh — Writ and Judicial Review | Chhattisgarh HC (2026)

What the court decided

AI extract

Outcome

Dismissed

Issue for consideration

Whether the writ petition is maintainable in view of the availability of an efficacious alternative statutory remedy (appeal under Section 40 of the Chhattisgarh Societies Registration Act, 1973), which the petitioner did not avail.

Court's answer

Absent exceptional circumstances — lack of jurisdiction, a natural justice violation of such a nature as to render the order void, or a challenge to the vires of a statutory provision — the extraordinary writ jurisdiction will not be invoked despite the availability of an efficacious alternative remedy; the petitioner demonstrated no such circumstance.

Ratio / Principle

Since the petitioner admittedly did not avail the efficacious statutory remedy of appeal under Section 40 of the Chhattisgarh Societies Registration Act, 1973, the Court declined to entertain the writ petition.

Key takeaways

The dismissal does not preclude the petitioner from availing the appeal under Section 40 of the Chhattisgarh Societies Registration Act, 1973; if such appeal is preferred, the appellate authority shall decide it on its own merits, uninfluenced by any observation in this order.ratio¶26

Detailed headnote1 paragraphs

Writ Petition (WPS) — Maintainability — Efficacious alternative statutory remedy — Petitioner, a District Social Audit Facilitator, challenged by writ under Article 226 the order dated 11.08.2025 reverting/demoting him to Block Social Audit Facilitator and reducing his honorarium from Rs.24,000/- to Rs.9,500/- — Held, no exceptional circumstance (lack of jurisdiction, natural-justice violation rendering the order void, or vires challenge) was shown warranting bypass of the statutory appellate remedy — Appeal lies under Section 40 of the Chhattisgarh Societies Registration Act, 1973, which was admittedly not availed — Writ petition dismissed as not maintainable — Dismissal shall not preclude the Section 40 appeal; appellate authority to decide on merits uninfluenced by observations in this order (Bibhu Datta Guru, J.).

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CGHC010362122025

2026:CGHC:30470

NAFR

HIGH COURT OF CHHATTISGARH AT BILASPUR

WPS No. 10047 of 2025

Anil Lahre S/o Shri Hiraram Lahre Aged About 30 Years R/o Old D.R.D.A. Building Collector Complex, Raipur (C.G.)

... Petitioner

versus

1 - State of Chhattisgarh Through Its Secretary, Department of Panchayat & Rural Development, Mahanadi Bhawan, Atal Nagar, Naya Raipur (C.G.)

2 - Chhattisgarh Social Audit Unit DRDA Building, Collector Complex, Raipur (C.G.)

3 - Collector Raipur, Collectorate, Kutchery Chowk, Raipur, Chhattisgarh

		... Respondents
For Petitioner	:	Mr. Shutubdi Bagchi, Advocate
For State	:	Mr. Vivek Verma, Advocate

(Hon’ble Shri Justice Bibhu Datta Guru)

Order on Board

17/07/2026

Digitally
signed by
ASHUTOSH
ASHUTOSH MISHRA
MISHRA Date:
2026.07.17
18:19:40
+0530

The present writ petition has been filed calling in question the order dated 11.08.2025, whereby the petitioner, who was working as District Social Audit Facilitator, has been reverted/demoted to the post of Block Social Audit Facilitator and his honorarium has been reduced from

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Rs.24,000/- to Rs.9,500/-.

At the outset, learned State counsel has raised a preliminary objection with regard to the maintainability of the writ petition on the ground of availability of an efficacious statutory alternative remedy. It is submitted that under Section 40 of the Chhattisgarh Societies Registration Act, 1973, an appeal lies against the order impugned herein and, without availing the said statutory remedy, the petitioner has directly approached this Court under Article 226 of the Constitution of India.

Learned counsel for the petitioner could not demonstrate the existence of any exceptional circumstance warranting bypassing the statutory appellate remedy. No case of lack of jurisdiction, violation of principles of natural justice of such nature as would render the order void, or challenge to the vires of any statutory provision has been made out so as to invoke the extraordinary writ jurisdiction despite availability of an efficacious alternative remedy.

In the present case, the petitioner has an efficacious statutory remedy of appeal under Section 40 of the Chhattisgarh Societies Registration Act, 1973, which has admittedly not been availed. Accordingly, this Court is not inclined to entertain the present writ petition.

The writ petition is dismissed as not maintainable on the ground of availability of an efficacious alternative statutory remedy. However, it is made clear that dismissal of the present petition shall not preclude the petitioner from availing the remedy of appeal available under Section 40 of the Chhattisgarh Societies Registration Act, 1973, in accordance with

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law. If such appeal is preferred, the appellate authority shall consider and decide the same on its own merits, uninfluenced by any observation made in this order.

SD/-

SD/- ( Bibhu Datta Guru ) JUDGE

ashu