Case brief
What is this about?
Patna High Court, C. REV. No.221 of 2024, decided 23-04-2026 by Rajesh Kumar Verma, J. (oral order). Review of order dated 01.07.2024 in CWJC No. 14105 of 2023 permitting withdrawal of the writ petition with liberty to challenge cancellation of membership before the appropriate forum. State's preliminary objection on maintainability; review grounds under Order 47 Rule 1 CPC; 'any other sufficient reason' held not to cover unclean-hands grievance; petitioners themselves sought withdrawal; no case for review; review petition dismissed. Parties: Munna Sahni and Gaighat Prakhand Matasyajivi Sahyog Samiti Ltd. v. State of Bihar and others incl. Balraj Sahni. Counsel: Deepak Kumar for petitioners; Additional Advocate General 12 for the State.
What did the court decide?
The expression 'any other sufficient reason' is not wide enough to include the perception that the petitioners had not approached the Court with clean hands; it would include only such grounds as are analogous to the other two stipulated grounds under Order 47 Rule 1 of the Code of Civil Procedure.