Madras High Court Dismisses Petition to Rename Tamil Nadu Government Department

Court Declares Naming and Renaming of Government Departments as Administrative Function Beyond Judicial Review

In a significant judgment, the Madras High Court dismissed a petition seeking the rechristening of the Tamil Nadu government department, Tamil Valarchi Thurai, to Tamil Membattu Thurai. The Division Bench, comprising Chief Justice Manindra Mohan Shrivastava and Justice G. Arul Murugan, ruled that the task of naming and renaming government departments falls within the exclusive domain of the state government and is not subject to judicial review under Article 226 of the Constitution of India.

The petitioner, Muthu Subramaniam, had approached the court after his request to rename the department was rejected by the authorities in December 2022. He argued that the term "Valarchi," meaning growth and enrichment, did not appropriately convey the concept of "development," which he believed should be better represented by the term "Membattu."

The court observed that all arguments presented by the petitioner had been duly considered by the respondent authorities, who found no grounds to alter the department's name. It noted that the authorities acted without any mala fides or arbitrariness, and the court lacked the expertise to intervene in such administrative decisions.

Furthermore, the court highlighted that the petition was filed nearly three years after the impugned order was issued, indicating a lack of compelling urgency. It emphasized that extraordinary jurisdiction under Article 226 could not be invoked in cases where delay and lack of urgency were apparent, especially when the issue did not have significant societal impact.

The bench concluded that the cause espoused by the petitioner was purely an administrative matter, best left to the discretion of experts in the field. As such, the Public Interest Litigation (PIL) was dismissed, with the court reiterating its limited role in administrative affairs.

Bottom Line:

Rechristening or renaming of government departments is purely within the domain of the Government, and such matters cannot be undertaken by the High Court while exercising writ jurisdiction under Article 226 of the Constitution of India.

Statutory provision(s): Article 226 of the Constitution of India

Muthu Subramaniam v. State Government of Tamilnadu, (Madras)(DB) : Law Finder Doc Id # 2812441