Dismissed¶37

P.Balasubramaniyam v. the Principal Secretary

Madras HC12 Jan 2026WP/27651/2025

Case brief

AI extract

What is this about?

locus standi; writ of mandamus; Article 226; personal grievance; public interest litigation; PIL; vengeance; family dispute; docket multiplication; father-in-law; daughter-in-law; divorce proceedings; Tamil Nadu Medical Council complaint dismissed 22.12.2025; bond service default; non-service PG candidate; M.S. General Surgery; state quota; PG Session 2016-2017; bond amount recovery; Rs.40 lakhs; Rs.40,00,000; Stanley Medical College letter 23.06.2025; Na.Ka.No.4699/Maka2/2025; Right to Information Act; costs Rs.2000; Madras High Court; 2026; writ dismissed with costs

What did the court decide?

No relief granted to the petitioner; writ petition dismissed with costs of Rs.2000/- payable by the petitioner to the 3rd respondent. ¶37

P.Balasubramaniyam Vs the Principal Secretary — Writ and Judicial Review | Madras HC (2026)

What the court decided

AI extract

Outcome

No relief granted to the petitioner; writ petition dismissed with costs of Rs.2000/- payable by the petitioner to the 3rd respondent.

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Issue for consideration

Whether the petitioner, said to be the father-in-law of the 5th respondent with divorce proceedings pending between her and the petitioner's son, has locus standi to maintain the writ petition seeking recovery of the bond amount from the 5th respondent. +1 more

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Court's answer

The petitioner is not personally aggrieved; having suppressed that the 5th respondent is his own daughter-in-law, he should, if at all, have filed the petition as a public interest litigation, which he did not do.

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Ratio / Principle

The jurisdiction under Article 226 of the Constitution of India cannot be invoked only to wreak vengeance.

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Key takeaways

Finding no merits in the writ petition, it is dismissed with costs of Rs.2000/- to be paid by the petitioner to the 3rd respondent.ratio¶37
Passing observation that there is no end to docket multiplication when it comes to family disputes, with such disputes spreading from Family Courts into other jurisdictions including Article 226 matters.obiter¶33

Detailed headnote1 paragraphs

Madras High Court (D. Bharatha Chakravarthy, J.), W.P.No.27651 of 2025, decided 12-01-2026 — Mandamus / Locus standi. The petitioner sought a writ of mandamus directing Health Department officials (respondents 1 to 4) to take action against the 5th respondent, a non-service PG (M.S. General Surgery, Session 2016-2017) candidate who completed the course in April 2019 without bond service, to recover Rs.40 lakhs per the Dean, Government Stanley Medical College's letter dated 23.06.2025 in Na.Ka.No.4699/Maka2/2025. The Government Advocate conceded recovery action was under way but questioned the petitioner's locus standi; the 5th respondent revealed the petitioner was her father-in-law, suppressing that pending divorce proceedings existed between her and his son, and that his earlier complaint to the Tamil Nadu Medical Council was dismissed by an eight-page order dated 22.12.2025. Holding the petitioner was not personally aggrieved and should have moved as a PIL if at all, and that Article 226 jurisdiction cannot be invoked 'only to wreak vengeance', the Court dismissed the writ petition with costs of Rs.2000/- payable to the 3rd respondent. Obiter: family disputes cause unending docket multiplication across courts, now encroaching on Article 226.

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W.P.No.27651 of 2025

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IN THE HIGH COURT OF JUDICATURE AT MADRAS

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DATED: 12-01-2026

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CORAM

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THE HONOURABLE MR.JUSTICE D.BHARATHA CHAKRAVARTHY

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W.P.No.27651 of 2025

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P.Balasubramaniyam, S/o. Pavadai, No.164 HIG NH-I, Rajiv Gandhi Street, Marimalai Nagar, Chengalpattu Taluk, Chengalpattu Distirct

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Petitioner

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1.The Principal Secretary to Government, Health And Family Welfare Department, Fort St. George, Government of Tamil Nadu, Chennai 600 009.

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2.The Dean, Government Stanley Medical College No.1 Old Jail Road, Chennai 600 001.

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3.The Director of Medical Education, No.162 EVR Periyar Salai, Kilpauk, Chennai 600 010.

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4.The Director of Public Health And Preventive Medicine, No.359 Anna Salai, Chennai-600 006.

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https://www.mhc.tn.gov.in/judis

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W.P.No.27651 of 2025

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5.Dr.Monika, S. 7/4, 3^rd Cross Street, Collectorate Colony, Aminjikarai, Chennai 600 029.

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Respondents

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PRAYER

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Writ Petition is filed under Article 226 of the Constitutio of India praying to issue a Writ of Mandamus directing the respondents 1 to 4 to take action against the 5^th respondent to recover the amount of Rs.40 lakhs as per the letter of the 2nd respondent dated 23.06.2025 made in Na.Ka.No. 4699/MaKa2/2025 within a time fixed by this Honourable Court.

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For Petitioner: Mr.P.Krishnan For Respondents: Mr. E.Sundaram, GA for R1 to R4 Mrs.N.Kavitha Rameswar for R5

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ORDER

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The Writ Petition is filed for a Writ of Mandamus directing the respondents 1 to 4 to take action against the 5^th respondent to recover the amount of Rs.40 lakhs as per the letter of the 2^nd respondent dated 23.06.2025 made in Na.Ka.No.4699/Maka2/2025, within the time fixed by this Hon’ble Court.

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Upon hearing the learned counsel for the petitioner and perusing the affidavit filed in support of the writ petition, the particulars about the 5^th respondent that she is a non-service PG candidate, who was selected under the state quota for M.S.(General Surgery) Post Graduate Degree Course during the

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https://www.mhc.tn.gov.in/judis

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W.P.No.27651 of 2025

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PG Session 2016-2017 in a Tamil Nadu Government Medical College and the fact that she completed the course in April 2019 and she has not done the bond service, and therefore, she is liable to pay Rs.40,00,000/-. It is also seen that

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number of queries were also made under the Right to Information Act and inspite thereof, the Authorities are not taking any action and therefore, the petitioner has made a representation and come before this Court with the above prayer.

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The learned Government Advocate appearing for the official respondents 1 to 4 would submit that it is true that the 5^th respondent was a nonservice candidate and the action is being taken with reference to her noncompliance of the bond period, however the petitioner has no locus standi to file the writ petition.

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The learned counsel appearing on behalf of the 5^th respondent would submit that the petitioner is none other than the father-in-law of the 5^th respondent and suppressing the said fact, the writ petition is filed. The divorce proceedings are pending between the 5^th respondent and the petitioner’s son. Already, the petitioner lodged a complaint before the Tamil Nadu Medical Council and an elaborate enquiry was also conducted and an order running up to eight pages was passed on 22.12.2025 dismissing the complaint of the petitioner.

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https://www.mhc.tn.gov.in/judis

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W.P.No.27651 of 2025

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I have considered the rival submissions made and perused the material records of the case.

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There is no end to docket multiplication, when it comes to family disputes. From the Family Courts, it is expanded to Criminal Courts and the other jurisdictions and now, slowly, all subjects under Article 226 of the Constitution of India are also being occupied for the dispute. If a family conflict arises between the husband and wife, the law enjoins that the parties should amicably try to discuss the issue, go for counselling before the Family Court and the Family Court may also refer the parties to Mediation to try to settle the issue. If the issue is not settled, they are supposed to go for trial and if a prayer is made for divorce or restitution of conjugal rights or maintenance, as the case may be, the Court will grant or refuse the relief depending on whether the grounds are made out or not. But, unfortunately, variety of litigations are filed for the family dispute.

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In this case also, a disgruntled father-in-law, by completely suppressing the fact that the 5^th respondent is his own daughter-in-law, has filed the writ petition. It is not even averred, how the petitioner is personally aggrieved in the writ petition. If the petitioner is not personally aggrieved, then the petition should have been filed as a public interest litigation and that is also not done.

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https://www.mhc.tn.gov.in/judis

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W.P.No.27651 of 2025

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Only to wreak vengeance, the jurisdiction under Article 226 of the Constitution of India, cannot be invoked. Therefore, finding no merits, the Writ Petition is dismissed, with costs of Rs.2000/- to be paid to the 3^rd respondent by the petitioner.

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12-01-2026

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Neutral Citation:Yes ari

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1.The Principal Secretary, to Government, Health and Family Welfare Department, Fort St. George, Government of Tamil Nadu, Chennai 60 0 009.

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2.The Dean Government Stanley Medical College No. 1 Old Jail Road, Chennai

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3.The Director of Medical Education No. 162 EVR Periyar Salai, Kilpauk Chennai 600 010.

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