Janki Devi vs The State Of Bihar on 15 July, 2026

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    Patna High Court

    Janki Devi vs The State Of Bihar on 15 July, 2026

    Author: Partha Sarthy

    Bench: Partha Sarthy

             IN THE HIGH COURT OF JUDICATURE AT PATNA
                        Civil Writ Jurisdiction Case No.5985 of 2026
    
         ======================================================
         Janki Devi Wife of Chulihai Ram, Resident of Village-Matiyariya, P.O.-
         Makhua, Turakauliya, P.S.-Harsiddhi, District-East Champaran. Presently
         Pramukh of Block Panchayat Samiti, Harsiddhi, East Champaran.
    
    
                                                                   ... ... Petitioner/s
                                            Versus
    
    1.   The State of Bihar through the Principal Secretary, Panchayati Raj
         Department, Government of Bihar, Patna.
    2.   Principal Secretary, Panchayati Raj Department, Government of Bihar,
         Patna.
    3.   District Magistrate, East Champaran, District-East Champaran.
    4.   Block Development Officer cum Executive Officer, Block Panchayat Samiti,
         Harsiddhi, East Champaran.
    5.   Aasma Praveen, wife of not known to the petitioner,
    6.   Mustaqeem Ansari, son of not known to the petitioner,
    7.   Deepak Kumar, son of not known to the petitioner,
    8.   Rizwana Khatoon, son of not known to the petitioner,
    9.   Braj Kishore Yadav, son of not known to the petitioner,
    10. Amzad Khan, son of not known to the petitioner,
    11. Pradeep Yadav, son of not known to the petitioner,
    12. Savitri Devi, wife of not known to the petitioner,
    13. Suresh Das, son of not known to the petitioner,
    14. Geeta Devi, Wife of not known to the petitioner,
    15. Wasima Khatoon, wife of not known to the petitioner,
    16. Shailendra Kumar, son of not known to the petitioner,
    17. Chanda Kumari, wife of not known to the petitioner,
    18. Shivji Yadav, son of not known to the petitioner,
    19. Suganti Devi, wife of not known to the petitioner,
    20. Sarfaraz Rai, son of not known to the petitioner,
    21. Geeta Devi, wife of not known to the petitioner,
        Respondent No.5 to 21 are elected members of Block Panchayat Samiti,
        Harsiddhi, Block-Harsiddi, P.S.-Harsiddhi District-East Champaran.
    22. Gulaichi Devi, Elected Member, Block Panchayat Samiti, Harsiddhi Block,
        Constituency No. 14- Respondent No. 22
    23. Razia Khatun, Elected Member, Block Panchayat Samiti, Harsiddhi Block,
        Constituency No. 20- Respondent No. 23
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      24. Subhasini Devi, Elected Member, Block Panchayat Samiti, Harsiddhi Block,
          Constituency No. 9- Respondent No. 24
      25. Prabha Devi, Elected Member, Block Panchayat Samiti, Harsiddhi Block,
          Constituency No. 5- Respondent No. 25
      26. State Election Commission, Bihar, through its Secretary, Sone Bhawan, 3rd
          Floor, Beer Chand Patel Marg, Patna- 800001- Respondent No. 26.
      27. Vijay Kumar Kushwaha son of Late Ramdas Prasad, Constituency No. 3.
          Elected Member - Block Panchayat Samiti. Harsiddhi Block. Resident of
          Village- Yadopur, Block- Harsiddhi East Champaran.
      28. Hasan Raja Miyan son of Amin Miyan, Constituency No. 18, Elected
          Member Block Panchayat Samiti, Harsiddhi Block, Resident of Village-
          Kritpur, Block -Harsiddhi East Champaran.
      29. Dinesh Prasad son of Jagarnath Prasad, Constituency No. 13, Elected
          Member -Block Panchayat Samiti, Harsiddhi Block, Resident of Village-
          Mathkohiyar, Block Harsiddhi East Champaran.
      30. Kanhaiya Prasad son of Shivnath Prasad, Constituency No. 15, Elected
          Member Block Panchayat Samiti, Harsiddhi Block, Resident of Village-
          Ghiwadar, Block Harsiddhi East Champaran.
    
    
                                                     ... ... Respondent/s
           ======================================================
           Appearance :
           For the Petitioner/s       : Mr. Niranjan Kumar, Advocate
           For the State              : Mr. Jitendra Kumar Roy-1, SC-13
                                         Mr. U.K. Singh, AC to SC-13
           For the SEC                : Mr. Ravi Ranjan, Advocate
           For the Pvt. Resp.         : Mr. SBK Manglam, Advocate
                                         Mr. Awnish Kumar, Advocate
                                         Mr. Vikash Kumar Singh, Advocate
           ======================================================
           CORAM: HONOURABLE MR. JUSTICE PARTHA SARTHY
    
                                         C.A.V. JUDGMENT
    
    
             Date : 15-07-2026
    
                           Heard Mr. Niranjan Kumar, learned counsel for the
    
             petitioner, Mr. U.K.Singh, learned counsel for the State of Bihar,
    
             Mr. Ravi Ranjan, learned counsel for the State Election
    
             Commission and Mr. S.B.K. Manglam, learned counsel for the
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             private respondents/requisitionists.
    
                     2. The petitioner filed the instant application for the
    
             following relief(s):
    
                              "I. That the present writ application is being filed in
                              the nature of a writ of Certiorari for quashing the
                              notice dated 01.04.2026 given by elected members
                              of Block Panchayat Samiti, Harsiddhi, East
                              Champaran, for convening a special meeting to
                              consider a No-Confidence Motion against the
                              Pramukh (Petitioner), alleging violation of the
                              section 44(3) of the Bihar Panchayat Raj Act, 2006
                              (hereinafter referred to as the 'Act, 2006'); as the
                              said notice is hit by principle of "Coram non judice"
                              (issued without legal authority or jurisdiction), it is
                              ultra vires, as it is hit by Section 44(3)(iii) of the
                              Act, 2006, the meeting is invalid;
                              II. That the present writ petition is being filed in the
                              nature of Mandamus, seeking a direction to the
                              respondents to desist from proceeding in terms of
                              Section 44(3)(iii) of the Act, 2006 and from
                              convening any special meeting for consideration of
                              a No-Confidence Motion against the Pramukh
                              (Petitioner), as the same is barred by law;
                              III. For any other relief(s) to which the Petitioner
                              may be found entitled in the facts and circumstances
                              of the case."
                     3. On an application being filed by the petitioner,
    
             additional reliefs to be prayed for by the petitioner were allowed
    
             which are as follows:
    
                              "IV. That the present writ application is being filed
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                              in the nature of Certiorari for quashing Letter No.
                              180 dated 20.04.2026 issued under the signature of
                              Block        Development      Officer,   Harsiddhi,     East
                              Champaran, by which a special meeting has been
                              called for a no-confidence motion against the
                              petitioner (Janki Devi Presently Pramukh of - Block
                              Panchayat Samiti, Harsiddhi, East Champaran).
                              V. That the present writ application is being filed to
                              set aside the proceedings of the special meeting
                              convened       by     the   Executive    Officer-cum-Block
                              Development Officer, pursuant to which a no-
                              confidence motion was carried out on 29.04.2026."
                     4. The petitioner, an elected Pramukh of Block Panchayat
    
             Samiti, Harsiddhi has filed the instant application challenging
    
             the notice dated 1.4.2026 given by the elected members of the
    
             Block Panchayat Samiti for convening the special meeting to
    
             consider       the       no      confidence       motion       against     the
    
             Pramukh/petitioner, to restrain the respondents from proceeding
    
             on the said letter, for quashing the letter dated 20.4.2026 issued
    
             under the signature of the Executive Officer/Block Development
    
             Officer, Harsiddhi fixing the date of meeting on 29.4.2026 at 11
    
             a.m. as also for quashing the proceedings of the meeting of the
    
             Panchayat Samiti held on 29.4.2026 wherein the no confidence
    
             motion was passed against the petitioner by 18 out of the 20
    
             members participating.
    
                     5. The case of the petitioner in brief is that she was
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             elected as a member of the Block Panchayat Samiti, Harsiddhi
    
             on 1.12.2021 and as a Pramukh on 13.3.2024. It is the case of
    
             the petitioner that she came to know through a facebook post
    
             that a notice dated 1.4.2026 has been issued for convening a
    
             special meeting to consider the no confidence motion against
    
             her on the charges as mentioned therein. A total of 17 out of 26
    
             elected members were shown to have taken the decision to
    
             convene a special meeting to consider the no confidence motion
    
             against her. The B.D.O. having issued a letter dated 20.4.2026
    
             for convening a special meeting on 29.4.2026 during pendency
    
             of the instant application and the said meeting having taken
    
             place wherein the no confidence motion was passed against the
    
             petitioner by 18 out of 20 members participating, the petitioner
    
             has also challenged the letter dated 20.4.2026 and the
    
             proceedings dated 29.4.2026 in the instant application.
    
                     6. Mr. Niranjan Kumar, learned counsel for the petitioner
    
             submits that the prayer made in the instant application is fit to
    
             be allowed on the grounds that 9 out of 17 members who
    
             requisitioned the meeting were not actually present nor had
    
             signed the requisition. Their signatures were forged and the
    
             respondents had played a fraud on the statute. The requisition
    
             was not presented to the Pramukh/petitioner as required under
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             section 44 of the Bihar Panchayat Raj Act, 2006 (hereinafter
    
             referred to as 'the Act'). The term of the petitioner as a Pramukh
    
             expired in August 2026, so no special meeting could be called in
    
             view of the provision contained in section 44(3)(iii) of the Act.
    
             The charges levelled in the requisition were vague, not specific
    
             and thus the requisition itself was bad. It was submitted that for
    
             all these reasons writ application was fit to be allowed, the
    
             orders impugned be set aside and the prayer made in paragraph
    
             no.1 be granted. In support of his contentions, learned counsel
    
             for the petitioner relied upon the judgments in the case of
    
             Sindhu Devi & Ors. vs. The State of Bihar & Ors.; 2002(1)
    
             PLJR 281(DB), Arti Kumari vs. State of Bihar & Ors.;
    
             2015(3) PLJR 276 and Santosh Kumar Rai & Anr. vs. State of
    
             Bihar & Ors.; 2019(2) PLJR 380.
    
                     7. The application is opposed by learned counsel
    
             appearing for the State of Bihar. Referring to the counter
    
             affidavit filed, it was submitted that the petitioner and other
    
             members of the Panchayat Samiti having been elected in
    
             November/December 2021, their terms would expire in
    
             November/December 2026. Thus section 44(3)(iii) of the Act
    
             has no application. It was further submitted that 17 of the
    
             elected members went to submit a no confidence motion to the
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             Pramukh on 1.4.2026, however as she was not available in the
    
             office and refused to meet the requisitionists at home, the same
    
             was submitted in original along with the photocopy in the office
    
             of the Executive Officer-cum-B.D.O. The B.D.O. sent a copy of
    
             the notice in original on 1.4.2026 to the office of the Pramukh
    
             by a peon which was refused. It was again sent to her residence
    
             on 2.4.2026 which was again refused. Thereafter the requisition
    
             was pasted on the front gate and photographs were taken. A
    
             copy of the requisition was also sent through electronic means.
    
             On the Pramukh not fixing the date in exercise of powers under
    
             section 44(3)(i), the date of special meeting was fixed on
    
             29.4.2026

    at 11 a.m. As would be evident from the noting of the

    peon on 21.4.2026, the information about the meeting going to

    SPONSORED

    be convened on 29.4.2026 at 11 a.m. was given to the Pramukh

    on 21.4.2026. 20 elected Panchayat Samiti members

    participated in the meeting on 29.4.2026 and the no confidence

    motion was passed by 18 votes to 2 in favour of the motion. It is

    further submitted that further directions have been given by the

    Joint Election Commissioner, State Election Commission, Bihar

    to the District Officer-cum-District Election Officer

    (Panchayat), East Champaran to conduct the election for

    Pramukh of Block Harsiddhi.

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    8. Learned counsel for the respondents State of Bihar

    further submitted that notice of the meeting having been served

    on the Pramukh on 21.4.2026, there was seven clear days

    between the date of service of notice and the date fixed for

    considering the no confidence motion ie 29.4.2026. On

    29.4.2026, the no confidence motion was passed by 18 out of 20

    elected members participating and thus by a majority of the total

    elected members which is 26. Thus, there being no merit in the

    writ application, the same be dismissed.

    9. Mr. S.B.K. Manglam, learned counsel appearing for the

    requisitionists/private respondents opposing the application

    submitted that all efforts having been made to present the

    requisition for calling special meeting to consider the no

    confidence motion against the Pramukh by the requisitionists to

    the Pramukh and they not having succeeded, they served the

    original as also a copy of the same as required under section

    44(1) of the Act before the B.D.O.-cum-Executive Officer. The

    attempts even by the B.D.O. to get the notice served on the

    Pramukh on 1.4.2026 at her office and on 2.4.2026 at her

    residence failed on account of her refusal and thereafter the

    requisition was pasted on the front gate and photographs taken.

    It is submitted that the petitioner accepts having received the
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    notice through electronic means and has also brought a copy of

    the same on record as Annexure P/4 to the writ application.

    After repeated attempts and inspite of service, no date of special

    meeting having been fixed, in exercise of powers under section

    44(3)(i) of the Act, the date of special meeting was fixed for

    29.4.2026 and the same was communicated by the Executive

    Officer to all the Panchayat Samiti members including the

    Pramukh by letter dated 20.4.2026. The notice was served on

    the Pramukh on 21.4.2026. After clear seven days of the service

    of notice, the special meeting was convened on 29.4.2026

    wherein 20 Panchayat Samiti members participated and 18

    voted in favour of no confidence motion. Thus with a majority

    of the elected members ie 18 out of 26 having voted to oust the

    Pramukh and the entire procedure having been followed in

    accordance with law, there is no merit in the instant application

    and the same be dismissed.

    10. Heard learned counsel for the parties and perused the

    material on record.

    11. The relevant facts in brief are that in the Block

    Panchayat Samiti consisting of total 26 members, the petitioner

    was elected as a member of the Panchayat Samiti on 1.12.2021

    and later as the Pramukh on 13.3.2024. On 1.4.2026, a
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    notice/requisition signed by 17 members of the Panchayat

    Samiti and addressed to the Pramukh requested the Pramukh to

    call for a special meeting to consider the no confidence motion

    against her on the grounds that she had acted arbitrarily by not

    calling the meeting of the Panchayat Samiti on time, giving

    preference to close associates in the standing committee, the

    resolution passed by the Panchayat Samiti not being

    implemented, tampering with the resolutions of the Panchayat

    Samiti, the funds being received for development not being

    distributed equitably, majority of the meetings being conducted

    not by the Pramukh but by her son and creating obstacles in the

    working of Panchayat Samiti. It transpires from the records that

    the requisitionists went to the official chamber of the Pramukh

    on 1.4.2026 to present the requisition, however she was absent.

    Thereafter they went to her residence but she refused to meet

    the requisitionists.

    12. It is the case of the requisitionists that the son of the

    Pramukh was present at the petitioner’s residence and was ready

    to start a quarrel. Avoiding any scuffle, the requisitionists

    returned and sent the original requisition along with the

    photocopy of the same to the Executive Officer. It further

    transpires that the Executive Officer on 1.4.2026 itself sent the
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    requisition through a peon to the Pramukh, however she once

    again refused to receive and the same was sent on 2.4.2026 to

    her house which was also refused. Thereafter the same was

    pasted at her house and photographs taken. The process was

    repeated on 3.4.2026 as also on 4.4.2026.

    13. No meeting having been fixed by the Pramukh as

    required under section 44(3) of the Act, on 20.4.2026, the

    requisitionists fixed the date for special meeting on 29.4.2026

    and requested the Executive Officer to issue notice of the

    special meeting to all the elected members. Accordingly, a

    notice dated 20.4.2026 was issued by the Executive Officer and

    it was received by the Pramukh on 21.4.2026. The special

    meeting took place on 29.4.2026 wherein 20 of the total 26

    elected members participated and the no confidence motion was

    passed against the Pramukh with 18 votes being cast in favour

    of the motion, being majority of the total elected members

    which is 26.

    14. So far as the contention of learned counsel for the

    petitioner that large number of persons have not signed on the

    requisition and their signatures have been forged, it may only be

    observed here that no such persons/requisitionists/respondents

    have appeared before this Court with any material in support of
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    the said contention made by the petitioner. Thus, the same has

    no legs to stand on.

    15. The next contention of the learned counsel for the

    petitioner is that the requisition was not presented to the

    Pramukh as required under section 44(3) of the Act and thus the

    same is not sustainable. From the contents of the affidavits on

    record it will clearly be evident that attempt was made by the

    requisitionists to present the requisition to the Pramukh on

    1.4.2026 both at her office as also her residence. Thereafter the

    Executive Officer sent the notice to her several times between

    1.4.2026 and 3.4.2026. On the petitioner’s refusal, the notice

    was pasted on the wall of the petitioner’s residence and

    photographs taken.

    16. So far as the judgment relied upon by the learned

    counsel for the petitioner is concerned, in the case of Sindhu

    Devi (supra), the very notice of the requisition did not indicate

    the grounds and the basis on which the action for motion of no

    confidence was contemplated. The charges and the allegations

    not having been mentioned in the requisition and the motion for

    no confidence having been passed by a majority even in absence

    of any charges, this Court held that it would not be the rule of a

    majority but would be mobocracy. The facts of this case are
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    clearly distinguishable in so far as the charges/allegations

    against the petitioner/Pramukh are clearly mentioned in the

    requisition dated 1.4.2026.

    17. In the case of Arti Kumari (supra), this Court noted

    that if a requisition though addressed to the Pramukh but if

    rooted through Executive Officer-cum-B.D.O. to be presented to

    the Pramukh, the same has been held to be an illegal procedure

    adopted by the requsitionists. So far as the facts of the instant

    case is concerned, the requisitionists have clearly stated that

    they made repeated attempts to present the requisition to the

    Pramukh and inspite of all efforts, having failed, the requisition

    was got served through the Executive Officer. The Pramukh

    having refused the service through the Executive Officer also

    lead to pasting of the requisition in the residence of the

    Pramukh. Thus, this judgment is of no assistance to the

    petitioner.

    18. The judgment in the case of Santosh Kumar Rai

    (supra) is also of no assistance to the petitioner in so far as there

    is detailed averment on affidavit both by the

    requisitionists/private respondents as also the Executive Officer-

    cum-B.D.O., firstly that the requisitionists attempted to present

    the requisition to the Pramukh and the requisitionists not having
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    succeeded either at the Pramukh’s office or her residence, the

    original as also a copy of the same was provided to the

    Executive Officer who also made attempts to get the same

    served. Ultimately the Pramukh having refused to receive the

    requisition, the same was finally pasted on her house and

    photographs taken.

    19. This Court in the case of Ramendra Ram vs. The

    State of Bihar; 2014(4) PLJR 413 has categorically held that

    when the provision requires the presentation of the requisition to

    the Pramukh, it does not mean that it can only be served

    personally upon him but all that is required is that the

    requisition should reach him. Relevant paragraphs of the

    judgment read as follows:

    “10. In so far as the issue of presentation of requisition
    is concerned, all that the provision requires is that the
    requisition should be presented to the Pramukh in
    writing with a copy to the Executive Officer. The mode
    and manner of presentation is not explained and thus
    the legislative intendment has to be seen for there may
    be circumstances where the Pramukh avoids service of
    notice and in such circumstances as well as in
    circumstances where the repeated efforts by the process
    server fails, all other options would be available to the
    Executive Officer to get it served, whether through
    registered post/speed post or in the manner provided
    under Order-V, rule 17 of the Code of Civil Procedure
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    all modes are available. When the provision requires
    the presentation of the requisition to the Pramukh it
    does not mean that it can only be served personally
    upon him by the requisitionists rather all that is
    required is that the requisition should reach the
    Pramukh and the manner in which it reaches becomes
    irrelevant, so long as the receipt is not in question.

    11. Thus any requisition which is addressed to the
    Pramukh and in particular circumstances where it
    cannot be served upon him, until such time that such
    requisition reaches the Pramukh in whatever mode and
    manner, no objection can be raised by the Pramukh on
    the manner of presentation. In so far as the present case
    is concerned it is the admission of the petitioners that
    they have received requisition by speed-post well in
    advance of the special meeting and thus the objection is
    only taken to be rejected.

    14. In the opinion of this Court whatever be the merits
    of the allegations, once they are put to motion and after
    following the lawful procedure, has resulted in the
    Pramukh/Up-Pramukh as the case may be, loosing the
    confidence of the house, there can be no judicial review
    either on the merits of allegations or the right of the
    members to maintain a second motion on identical
    allegations. A discussion on the allegations as provided
    under Section 44(3)(vi) would gain relevance only
    where there is opposition to it or where the
    Pramukh/Up-Pramukh decides to contest the same and
    vindicate their stand. It is an opportunity provided to
    the holder of the post and may be of a persuasive value
    but the outcome of the motion lies in the secret voting
    and if the same goes in favour of the no confidence
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    motion, the outgoing Pramukh/Up-Pramukh would have
    to honour the view of the house unless it suffers from
    procedural infraction.

    15. In so far as the present case is concerned the
    petitioners having lost the confidence of the house with
    no legal infirmities in the no confidence motion passed
    against them, they have no right to continue.”

    20. In the case of Priyanka Devi vs. The State of Bihar

    (order dated 17.2.2026 in LPA no.941 of 2024), a Division

    Bench of this Court held as follows:

    “44. The learned Senior Counsel on behalf
    of the respondent Nos. 4 to 7 next refers to a
    reported judgment of the Division Bench of this
    Court in Sabila Khatoon & Ors. vs. State of Bihar
    & Ors.
    , 2016 SCC OnLine Pat 10413: (2017) 2
    PLJR 29. This case relates to consideration of No
    Confidence Motion requisitioned by the Councillors
    against the Chairman of a Municipality under the
    Bihar Municipal Act, 2007. Paragraph Nos. 7 & 8
    of the said report clearly recording the following:-

    “7. A perusal of the said provision shows that
    requisition has to be given to Chief Councillor. The
    provision does not satisfy that it has to be Denise
    delivered to the Chief Councillor personally. It can
    be received by any person on her behalf. The
    requirement of serving of requisition personally on
    the Chief Councillor is otherwise also not possible
    as the person against her No Confidence is
    proposed always can go hiding or otherwise delay
    the receipt of requisition defeating the purpose of
    sending the requisition itself. Such is the view taken
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    by a Division Bench of this Court in LP.A. No. 1077
    of 2014 (Rajeshwar Prasad v. The State of Bihar)
    decided on 4.8.2014 wherein the Court pichas held
    the fact.

    Relevant extract reads as under :-

    18. While answering the question, posed above,
    it needs to be borne in mind that it is the
    fundamental rule of the interpretation of statutes
    that a word, appearing in the statute, shall be given
    its ordinary meaning and nothing shall be added to
    the statutory provisions or substracted therefrom.
    When the word “personally” does not appear in the
    statutory provisions embodied in Rule 2(i) of 2010
    Rules, it will be wholly unreasonable to insist that a
    requisition under Rule 2(i) of 2010 Rules shall be
    given “personally” to the Chief Councillor
    demanding holding of special meeting.

    19. When Rule 2(1) of 2010 Rules, nowhere,
    makes it obligatory, on the part of requisitionists, to
    give a Chief Councillor requisition for special
    meeting “personally” Rule 2(1) of 2010 Rules
    cannot be interpreted to either impose an obligation
    on the elected members, as requisitionists, to
    present “personally” to the Chief Councillor the
    requisition nor can it be said that the Chief
    Councillor shall be given requisition, “personally”.

    If Rule 2(i) of 2010 Rules is interpreted to convey
    what Mr. Giri attributes to the provisions contained
    in Rule 2 (i) of 2010, Rules, the consequences may
    be disastrous inasmuch as a Chief Councillor can
    always avoid personal service of a requisition and
    would, thus, not call for any special meeting and
    Patna High Court CWJC No.5985 of 2026 dt.15-07-2026
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    thereby frustrate the whole purpose of no
    confidence motion and bring, as a sequel thereto, a
    complete collapse of a democratic institution, such
    as, Panchayat.”

    8. In view of the Division Bench Judgment
    wherein the similar issue was raised and decided,
    we find that the order of learned Single Bench
    holding that the requisition has to be served
    personally on the Chief Councillor cannot be
    sustained. Thus, the No Confidence Motion passed
    against the writ applicant in the meeting held on
    15.10.2016 does not suffer from any illegality
    warranting interference in the writ application.
    There is another reason as to why the writ applicant
    is not entitled to any indulgence. After No
    Confidence Motion was carried out against the writ
    applicant, the fresh election was convened for 11th
    November, 2016. Though, this Court has ordered
    that the result shall not be declared but the
    applicant contested the post of Chief Councillor,
    therefore, in view of the judgment of this Court as
    reported (2010) 1 PLJR 929-Smt. Shamshad Khatun
    v. The State of Bihar
    , and (2010) 3 PLJR 98- Sanjay
    Kumar Mahajan v. State of Bihar
    , the writ applicant
    is estopped to challenge her removal. It has been
    held that once the person takes a chance and
    contests the election, even though a dispute may be
    sub judice before the court, cannot be allowed to
    challenge his/her very removal from the post which
    led to holding of the subsequent election. In view of
    the aforesaid judgment as well, we find that the writ
    applicant cannot be permitted to dispute the passing
    Patna High Court CWJC No.5985 of 2026 dt.15-07-2026
    19/21

    of the No Confidence Motion having participated in
    the election held on 11th of November, 2016.”

    45. Thus, it is contended by the learned
    Senior Counsel on behalf of the respondent Nos.4 to
    7 that the provision of Section 44(3) of the Bihar
    Panchayat Raj Act, 2006, which is pari materia to
    Section 25(4) of the Bihar Municipal Act, 2007 does
    not satisfy that the requisition for No Confidence
    Motion has to be delivered to the Chief Councillor
    personally, it can be received by any person on her
    behalf. The requirement of serving of requisition
    personally on the Prakhand Pramukh is otherwise
    also not possible, as the person against whom No
    Confidence is proposed, always can go hiding or
    otherwise delay the receipt of requisition, defeating
    the purpose of sending the requisition itself.”

    21. As held in the case of Priyanka Devi (supra), so far as

    the facts of the instant case are concerned, herein also section

    44(3) of the Act requires the requisition to be presented by the

    requisitionists to the Pramukh but there is no requirement that

    the same be presented personally.

    22. In view of the above, taking into consideration the

    facts and circumstances of the case wherein the Pramukh

    against whom the no confidence motion is moved avoids service

    of notice, he/she in a given case may defeat the purpose and

    indefinitely delayed the convening of the special meeting to

    consider the no confidence motion.

    Patna High Court CWJC No.5985 of 2026 dt.15-07-2026
    20/21

    23. So far as the facts of the instant case is concerned, not

    only the requisitionists moved to present the requisition on the

    Pramukh on 1.4.2026 but repeated attempts were made at both

    her office as also her residence firstly by the requisitionists and

    then on several dates between 1.4.2026 to 3.4.2026 by the

    Executive Officer who sent the requisition in original through a

    peon. On repeated refusal to receive the notice, the requisition

    was pasted at the house of the Pramukh, photographs taken and

    on the Pramukh not fixing the date for special meeting, the

    members of the Panchayat Samiti fixed the meeting which was

    communicated by the Executive Officer by his notice dated

    20.4.2026. The notice was received by the Pramukh on

    21.4.2026.

    24. As fixed, the special meeting took place on 29.4.2026

    wherein 20 Panchayat Samiti members participated and 18

    voted in favour of the no confidence motion. Thus, the position

    remains that the no confidence motion has been voted by a

    majority (18 out of 26) of the total elected members against the

    Pramukh.

    25. The Court finds no illegality in either the requisition

    dated 1.4.2026 of the 17 requisitionists, the letter dated

    20.4.2026 of the Executive Officer fixing the special meeting or
    Patna High Court CWJC No.5985 of 2026 dt.15-07-2026
    21/21

    the proceedings of the special meeting held on 29.4.2026.

    26. The Court finds no merit in the instant writ application

    and the same is dismissed.

    (Partha Sarthy, J)
    Saurabh/-

    AFR/NAFR
    CAV DATE                  07.07.2026
    Uploading Date            15.07.2026
    Transmission Date         N/A
     



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