Supreme Court Dismisses Challenge to Revised Estimates in Lift Irrigation Project, Upholds High Court’s Refusal to Order CBI Probe

A bench of Justices B.V. Nagarathna and Satish Chandra Sharma heard the Special Leave Petition filed against the Division Bench of the High Court of Judicature at Hyderabad which had dismissed a public interest writ petition challenging the revision of estimates for Electro Mechanical (E&M) equipment in the Palamuru Ranga Reddy Lift Irrigation Scheme (PRRLIS). The petitioner contested the revision of package estimates and sought both a declaration of fraud and a direction for a Central Bureau of Investigation (CBI) probe.

The Supreme Court declined to interfere with the High Court’s order and dismissed the Special Leave Petition. The Court held that the principal relief sought — a declaration that the respondents “fraudulently” revised estimates — required factual adjudication not appropriate for a writ under Article 226, and that the High Court did not err in declining to exercise its discretion to refer the matter to the CBI. The Court reiterated that it would not “sit in judgment over the non-exercise of discretion” by the High Court in directing an investigation. The Court, in its reasoning, observed: “As far as the first prayer is concerned, it is for a declaration that the action of respondent nos.1 to 7 was fraudulent in revising the estimates of the project in question. We find that those are aspects which would call for determination of facts or in other words, a factual adjudication which cannot be done in a writ petition filed under Article 226 of the Constitution of India.” The Court further noted, quoting the judgment, that “We do not think that in this Special Leave Petition, we can sit in judgment over the non-exercise of discretion in favour of the petitioner herein...”

Background The petitioner, Nagam Janardhan Reddy — a six-time MLA and former minister who had also chaired the Public Accounts Committee — filed Writ Petition (PIL) No.338 of 2017 in the Hyderabad High Court. He alleged that respondents 1–7 revised the estimated cost of E&M equipment for PRRLIS packages 1, 5, 8 and 16 from Rs.5,960.79 crore (as estimated by the Engineering Staff College of India) to Rs.8,386.86 crore, thereby causing a loss of Rs.2,426.07 crore to the public exchequer. The writ sought (i) a mandamus declaring the revision illegal, arbitrary and fraudulent and setting aside consequential actions, and (ii) a direction to respondent no.10 (CBI) to investigate and report to the Court.

The High Court considered these prayers and dismissed the writ petition by order dated 3 December 2018. The petitioner alleged that the High Court summarily rejected the claim and ought to have referred the matter for investigation or otherwise examined records in depth. The respondents countered that prior PILs filed by the same petitioner had raised substantially similar grievances (PIL Nos. 28/2016 and 179/2016) and that certain aspects were res judicata or barred by constructive res judicata. They further relied on an Office Memorandum of the Central Vigilance Commission (CVC) dated 12 September 2017 which had examined the complaint relating to PRRLIS packages 5 and 8 and found the complaint “false” and “unsubstantiated.”

The Supreme Court analysed whether the High Court erred in refusing to refer the matter for a CBI probe and whether the subject matter was amenable to relief in a writ petition. The Court held that the key contention of fraudulent revision raised questions of fact requiring adjudication beyond the scope of an Article 226 writ. It found the High Court had considered the petitioner’s contentions and was justified in declining to exercise its discretion to order a CBI investigation, particularly in view of antecedent proceedings and the CVC’s earlier finding. The SLP was dismissed and pending applications were disposed of.

Case Details: Case No.: 2025 INSC 798 (SLP (C) No.7005 of 2019) Case Title: Nagam Janardhan Reddy v. State of Telangana & Others Appearances: For the Petitioner(s): Shri Prashant Bhushan, Advocate For the Respondent(s): Senior counsel for respondent no.1/State and counsels for respective respondents (as per record)

Date of Order: May 21, 2025 Bench: Hon’ble Justices B.V. Nagarathna and Satish Chandra Sharma