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Urmila Devi v. The State of Uttar Pradesh & Ors.

Civil Appeal · 2026 INSC 471Decided 11 May 2026
C.A. No.-007427-007427 - 2026 (arising out of SLP(C) No. 9638/2023)
Justice Aravind Kumar · Justice Prasanna B. Varale

Background

Urmila Devi and Manoj Devi (Respondent No. 3) contested the 2021 Gram Panchayat Pradhan election for Parauli Suhagpur village, Etah district, UP, with Urmila Devi losing by just 2 votes. She filed an election petition alleging serious irregularities in the vote counting and sought a recount. The Prescribed Authority (Sub-Divisional Officer) first ordered a recount (05.11.2022) and, after the recount was conducted, passed a further order (17.03.2023) declaring Urmila Devi the winner. The High Court set aside this second order, holding the Prescribed Authority had become "functus officio" (lost its authority) after passing its first, final order.

Decision Breakdown

The Supreme Court examined whether the Prescribed Authority's first order (directing a recount) was truly "final" or merely interim in nature. It found that, unlike a precedent cited where the first order was interim, the recount order here comprehensively allowed the appellant's application and left nothing further to decide, making it a final order. Once that final order was passed, the Prescribed Authority became functus officio and had no legal power to pass the subsequent order declaring Urmila Devi elected. The Court therefore upheld the High Court's decision and dismissed the appeal, while also directing the Prescribed Authority concerned to be more cautious in handling election petitions in future.

Lesson Learnt

A quasi-judicial or statutory authority that has already passed a final, conclusive order on a matter loses the power to revisit or issue further orders on the same issue. It becomes "functus officio." Litigants and authorities alike must ensure procedural finality is respected once a decision fully disposes of an application.

Official source (sci.gov.in)View Judgment (PDF)

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