General Manager, R.B.I. v. N. Venkateshaiah & Ors.
Background
The Reserve Bank of India had required the Registrar of Co-operative Societies, Karnataka, to supersede the managing committees of two co-operative banks (Grain Merchants Co-operative Bank and Kannika Parameshwari Co-operative Bank) under Section 30(5) of the Karnataka Co-operative Societies Act, 1959, citing depositor protection. The Karnataka High Court quashed the supersession, holding that RBI was legally required to give the bank a hearing before making such a requisition, and RBI appealed to the Supreme Court.
Decision Breakdown
By the time the appeal was heard, fresh elections to the banks' managing committees had already been held twice, and both sides agreed it was no longer necessary for the Court to resolve the underlying legal question. The Supreme Court therefore disposed of the appeals without deciding whether a pre-decisional hearing by RBI is mandatory before it requisitions supersession of a co-operative bank's committee, explicitly leaving that question open "to be decided in an appropriate case where the situation so warrants," and directing that the High Court's judgment on the point not be treated as a precedent.
Lesson Learnt
When intervening events (like fresh elections already held) make a legal dispute moot, courts may close the case without settling the broader legal question, and will often say so expressly, so such a disposal should not be read as endorsing or rejecting the lower court's reasoning on that point.