Umakant Saran v State of Bihar
Rule established
Mandamus lies to compel a public authority to exercise a statutory discretion it has refused to exercise; it cannot direct the outcome of that discretion.
Facts
- Petitioner applied for a government appointment
- The authority refused to consider the application at all (refused to exercise discretion)
- Mandamus was sought to compel the authority to consider the application
Issue
- Whether mandamus lies to compel an authority to exercise a discretion it has wrongly refused to exercise?
Held
- Mandamus lies to compel an authority to exercise a discretion it has wrongly refused to exercise. The writ directs consideration, not a favourable outcome.
Ratio Decidendi
Mandamus directs the exercise of discretion, not its outcome. Refusal to exercise discretion at all is amenable to mandamus. The result of a properly exercised discretion is beyond the writ.
How to use it in an exam
Core distinction for ADM-5.2: mandamus commands consideration, not a favourable decision.
Source
Source: AIR 1973 Supreme Court 964
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.