Allowed

Amarjit Angom v. State of Manipur and 2 Ors.

Manipur HC8 Sept 2026MC(WP(C))/197/2025

Case brief

AI extract

What is this about?

The High Court of Manipur allowed an amendment application to a writ petition. The applicant sought to add prayers for quashing the graduate and diploma certificates of a respondent who was promoted. The Court held that allowing the amendment would not cause irreparable injury and would prevent the main petition from becoming futile.

What did the court decide?

Amendment application allowed; Applicant directed to file a recast petition within one week.

Amarjit Angom Vs State of Manipur and 2 Ors. — Service and Employment | Manipur HC (2026)

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Digitally signed LAISHRA by LAISHRAM M DHAKESHORI DEVI DHAKESH Date: ORI DEVI 2026.09.11 11:56:54 +05'30'

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Item No. 31

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IN THE HIGH COURT OF MANIPUR AT IMPHAL

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MC(WP(C)) No. 197 of 2025 Ref. WP(C) No. 69 of 2025 Amarjit Angom

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… Applicant/s

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Vrs.

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State of Manipur & 2 ors. … Respondent/s

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-B E F O R E-

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HON'BLE MR. JUSTICE AHANTHEM BIMOL SINGH

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09.09.2026

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Mr. T. Rajendra, learned senior advocate assisted by Mr. Sh. Bikash Sharma, learned counsel appeared on behalf of the applicant ; Mr. Shyam Sharma, learned GA appeared on behalf of respondent Nos. 1 & 2 ; Mr. N. Umakanta, learned senior advocate assisted by Ms. Kh. Sapna, learned counsel appeared on behalf of respondent No. 3 and Mr. Deepak Prasad Sahu, learned counsel appeared on behalf of respondent No. 5. No one appeared on behalf of respondent Nos. 4, 6 & 7.

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[2] The present application has been filed with a prayer for allowing the applicant to amend the pleadings made by him in the writ petition filed by him which is registered as WP(C) No. 69 of 2025. The proposed amendment as contained in paragraph No. 4 of the present application are as under –

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“ PROPOSED AMENDMENT

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“ I. In the facts and circumstances stated above, the diploma

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and degree certificate (at Annexure A/11 and A/12)

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MC(WP(C)) NO. 197 OF 2025

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respectively of the Respondent No. 3 are not valid in the eye of law and the same are null and void. Therefore, a writ of certiorari for quashing/setting aside the diploma and degree certificate of the Respondent No. 3 (at Annexure A/11 and A/12 is very much required to be passed

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The above be allowed to be added as a sub para after

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the existing para No. 16 of the writ petition.

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“ II. Issue rule nisi calling upon the Respondents to show cause as to why a writ of certiorari for quashing/setting aside the diploma and degree certificate (at Annexure A/11 and A/12) respectively of the respondent No. 3 shall not be issued.

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The above may be allowed to be inserted as para no.

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(i)a of the prayer made in para no. 27 of the writ

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petition. ”

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[3] The learned senior advocate appearing for the applicant submitted that the aforesaid writ petition was filed by the petitioner with the prayers, inter alia, for quashing and setting aside the order dated 0710-2024 issued by the Director (Social Welfare), Manipur, in so far as the respondent No. 3 is concerned. By the said impugned order dated 07-102024, both the applicant as well as the respondent No. 3 were appointed

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MC(WP(C)) NO. 197 OF 2025

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as Graduate Teachers by promotion in the Government Ideal Blind School

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of Social Welfare Department, Manipur.

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[4] It has been submitted on behalf of the applicant that the grounds raised by the applicant in the said writ petition in challenging the said impugned order are that the respondent No. 3 obtained the degree certificate and diploma certificate, which are essential qualification required for such promotion, were obtained simultaneously at the same time. According to the learned senior counsel, obtaining of the said Graduate degree and diploma certificate simultaneously at the same time is not permissible in the eyes of law. It has further been submitted on behalf of the applicant that even though such ground has been raised while challenging the impugned promotion order, through bonafide mistake, the petitioner did not make a prayer for quashing the said Graduation certificate as well as the Diploma certificate obtained by the respondent No. 3. Hence, the present amendment application has been filed for allowing the applicant to incorporate the proposed amendments in the writ petition by way of amendment.

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[5] The learned senior counsel, further, submitted that neither any fresh document nor any new pleadings have been brought in the proposed amendment and that all the necessary pleadings as well as the documents have already been enclosed in the writ petition. According to the learned senior counsel appearing for the applicant, the proposed

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amendment will not make out any new case and that unless such amendment is allowed, the writ petition filed by the petitioner will be rendered futile. The learned senior counsel, accordingly, prays for allowing the amendment application.

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[6] Mr. N. Umakanta, learned senior counsel appearing on behalf of respondent No. 3 raised three objections in opposing the present amendment application. The 1^st ground raised by the learned senior counsel is that the petitioner has no Locus Standi or any cause to seek for quashing the Graduate certificate as well as Diploma certificate obtained by the respondent No. 3. It has been submitted that the Diploma as well as the Degree certificate have been obtained by the respondent No. 3 from the competent University and Institute after having fulfilled all the necessary criteria, qualifications as well as after passing the requisite examination and that the applicant has no business whatsoever to seek for incorporating the prayers made in the proposed amendment.

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[7] The 2^nd ground raised by the learned senior counsel appearing on behalf of the respondent No. 3 is that the applicant has no business whatsoever to seek for incorporating the prayers made in the proposed amendment and that such proposed amendment will change the nature and character of the writ petition altogether. It has been submitted that the applicant initially challenged only the promotion of the respondent No. 3, however, by the propose amendment, the applicant is trying to change

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the writ petition concerning service matter into a personal vendetta petition.

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[8] The 3^rd ground raised on behalf of the respondent No. 3 is that the correctness of the Diploma and Degree certificates obtained by the respondent No. 3, if at all any irregularity is there, the same is to be examined by the concerned/competent authority i.e. the respondent No. 6 & 7 and that the applicant never approached the said competent authority complaining or alleging any kind of disparity or irregularity with the said Degree as well as the Dimploma certificate obtained by the respondent No. 3.

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[9] According to the learned senior counsel, without prior complaint or even without a whisper of a protest to the competent and concerned authority about the Degree and Dimploma certificate obtained by the respondent No. 3, the proposed amendment sought to be made by the present applicant is not only premature but the same cannot be permitted. The learned senior counsel, accordingly, prays for rejecting the present amendment application.

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[10] Mr. Shyam Sharma, learned GA appearing for respondent Nos. 1 & 2, despite failing to file any objection to the present amendment application, submitted that if the proposed amendment application is allowed, it will amounts to another fresh cause of action, which is not

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permissible. The learned GA, further submitted that he endorsed all the submission made on behalf of respondent No. 3.

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[11] I have considered, the rival submissions advanced by all the learned counsel appearing for the parties and also carefully examined all the materials available on record. With regard to the objection raised on behalf of the respondent No.3, it is to be pointed out that even after allowing the proposed amendment application, the question of Locus Standi as well as the validity of the Graduation certificate as well as Diploma certificate of the respondent No. 3 can still be examined and that such objection can be raised by the respondents during the course of the proceeding of the connected writ petition. Therefore, this Court is of the considered view that by allowing the present amendment application, no irreparable injury will be caused either to the State Government or to the respondent No. 3.

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[12] On the other hand, if the present amendment application is rejected, this Court is of the considered view that there is sufficient force in the submission made on behalf of the applicant that the connected writ petition will be rendered futile. In any case, it is trite in law that amendment can be allowed at any stage of the proceeding and in the present case, the proceeding is at the initial stage and is yet to be posted for hearing. Therefore, this Court is of the view that in the event of allowing such an

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amendment, all the respondents will have ample opportunity to raise any objection with regard to the challenge being made in the said writ petition. [13] For the findings and the reasonings made hereinabove, this Court is of the view that it will be in the interest of justice to allow the present amendment application. Accordingly, the present amendment application is hereby allowed. Applicant is directed to file a recast petition of the WP(C) No. 69 of 2025 within a period of one week from today.

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[14] With the aforesaid directions, the present application stands

disposed of.

JUDGE

Dhakeshori

MC(WP(C)) NO. 197 OF 2025

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Amarjit Angom v. State of Manipur and 2 Ors.

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Amarjit Angom v. State of Manipur and 2 Ors.

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