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SC: High Court cannot make parties worse off or order vigilance probe beyond pleadings—directions quashed

SC: High Court cannot make parties worse off or order vigilance probe beyond pleadings—directions quashed

Case Name: P. Radhakrishnan & Anr. v. Cochin Devaswom Board & Ors.

Citation: Civil Appeal No. 11902 of 2025 (arising out of SLP (C) No. 23740 of 2023)

Date of Judgment: 10 October 2025

Bench: Justice Dipankar Datta and Justice K.V. Viswanathan

Held: The Supreme Court held that the High Court exceeded its jurisdiction by issuing directions beyond the scope of the pleadings, particularly ordering a vigilance inquiry and directing refixation of license fees without notice to the affected parties. It reiterated that a litigant approaching a writ court cannot be made worse off by seeking relief. Courts must decide only on issues raised, and if compelled to travel beyond, must first put parties on notice in keeping with natural justice.

Summary: The appellants, representing the Chinmaya Mission Educational and Cultural Trust, challenged a 2014 order of the Cochin Devaswom Board enhancing their licence fee from ₹227.25 to ₹1,50,000 per annum for land allotted in 1974 for cultural and religious purposes. The Kerala High Court upheld the fee enhancement but also directed the Board to refix licence fees afresh under T. Krishnakumar v. Cochin Devaswom Board and to conduct a vigilance probe into the original lease. The Supreme Court found these directions unjustified, observing that the appellants had accepted the fee hike and were never put on notice regarding any enquiry. The Court emphasized that sweeping directions beyond pleadings can prejudice litigants and deter citizens from seeking redress. It reaffirmed that judicial pronouncements must observe restraint and that no writ petitioner should face an adverse outcome not sought in the proceedings.

Decision: Appeal partly allowed. The Supreme Court expunged the High Court’s directions ordering license refixation and vigilance enquiry but allowed the Board to enhance license fees independently in accordance with law. The appellants were directed to pay the remaining arrears of the revised license fee within three months. No order as to costs.

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