Judicial Restraint in Administrative Nomenclature:
Limits of Article 226 in Renaming Government Departments

1. Introduction

In Muthu Subramaniam v. State Government of Tamil Nadu, W.P. No. 43202 of 2025, decided on 14.11.2025, a Division Bench of the Madras High Court (Manindra Mohan Shrivastava, C.J. and G. Arul Murugan, J.) was called upon to examine whether the High Court, in its writ jurisdiction under Article 226 of the Constitution, could direct the State Government to change the name of a government department.

The petitioner sought a seemingly narrow but, in his view, culturally significant relief: to direct the State to rename the department currently called “Tamil Valarchi Thurai” (jkpH; tsh;r;rpj; Jiw – literally “Tamil Development Department”) as “Tamil Membattu Thurai” (jkpH; nkk;ghl;L Jiw – “Tamil Upliftment Department”) and to correspondingly alter the name of its Directorate.

The petition was framed as a Public Interest Litigation (PIL) under Article 226, styled as a writ of certiorarified mandamus, assailing the rejection order dated 14.12.2022 passed by the second respondent and seeking a consequential mandamus to adopt the petitioner’s preferred nomenclature.

The judgment is important not because it resolves a contentious constitutional dispute, but because it reaffirms and sharpens certain core principles:

The limits of judicial review over purely administrative and policy matters, such as nomenclature of departments.
The threshold for maintainability of PILs, particularly the requirement of public importance and “gravitas”.
The role of delay (laches) and the absence of mala fides or arbitrariness in refusing extraordinary relief.

2. Summary of the Judgment

The Court dismissed the writ petition (treated as PIL), holding that:

Naming and renaming of government departments lies exclusively within the domain of the executive (Government). It is a matter of administrative policy and expertise. The High Court, exercising writ jurisdiction under Article 226, cannot undertake this task.
The impugned order dated 14.12.2022 rejecting the petitioner’s request does not suffer from mala fides or arbitrariness. The Court observes that the actions of the authorities appear “whiter than white” in the absence of any concrete material indicating illegality or bad faith.
The challenge is marred by delay. The order was passed in December 2022, but the writ petition was filed nearly three years later, indicating no compelling urgency warranting exercise of the Court’s “extraordinary jurisdiction”.
The issue lacks the necessary public importance or societal impact for a PIL. Disputes over the precise linguistic rendering of the word “development” into Tamil may have academic or cultural interest, but they do not, in the Court’s view, represent a public cause of sufficient gravitas whose non-redressal would “impair the society at large”.
Given the above, the Court declines to exercise its jurisdiction under Article 226 and dismisses the PIL without costs, also closing the connected miscellaneous petition.

3. Detailed Analysis

3.1. Factual Background and Issues

The petitioner, Muthu Subramaniam, a resident of Udumalpet, Tiruppur District, asserted that Tamil scholars have repeatedly stated that the English word “development” is not accurately translated by the Tamil word “valarchi”, which, he argued, denotes:

growth,
increase,
enrichment,

whereas “development” connotes:

a higher state,
upliftment,
betterment.

On this linguistic and semantic basis, he submitted representations to the government seeking a change of the department’s name from Tamil Valarchi Thurai to Tamil Membattu Thurai. The competent authority rejected his request by proceedings dated 14.12.2022. The present writ petition sought:

Certiorarified mandamus to:
- quash the impugned order rejecting his request; and
- direct the respondents to effect the renaming and issue appropriate Government Orders (G.O.s).

Though styled as a PIL, the petition essentially raised the following legal issues:

Whether the High Court, under Article 226, can direct the State Government to rename a department.
Whether the government’s refusal to change the name is arbitrary, mala fide, or vitiated by non-application of mind.
Whether a PIL involving a dispute over the semantics of departmental nomenclature meets the threshold for public interest.
Whether the delay of nearly three years in challenging the order bars relief.

3.2. Precedential Context and Doctrinal Foundations

The order itself is brief and does not expressly cite specific case law. However, the reasoning is firmly grounded in established constitutional and administrative law principles developed by the Supreme Court of India and followed by High Courts. The judgment implicitly draws on, and is consistent with, the following established doctrinal strands:

3.2.1. Separation of Powers and Policy Domain of the Executive

The Court emphasises that the naming and renaming of government departments is “purely within the domain of the Government” and part of “governmental fiefdom”. This language reflects the broader principle that:

Courts do not ordinarily substitute their own views for those of the executive in policy matters.
Judicial review is limited to examining legality, constitutionality, and basic standards of reasonableness.

This approach is consonant with long-standing Supreme Court authority on separation of powers, where courts have held that they cannot sit in judgment over the wisdom of policy decisions, so long as they do not infringe constitutional or statutory limits.

3.2.2. Judicial Review of Administrative Action

The Court’s insistence on the absence of mala fides, arbitrariness, or non-application of mind mirrors the classic grounds of judicial review of administrative decisions:

Illegality (acting without or beyond legal authority),
Irrationality/unreasonableness (commonly associated with the Wednesbury standard),
Procedural impropriety, and
Violation of fundamental rights or constitutional norms (especially Article 14).

The observation that the authorities’ actions are “whiter than white” – absent any evidence to the contrary – is a colourful way of saying that none of these grounds are made out.

3.2.3. PIL Jurisprudence: Threshold of Public Interest

The Court’s remarks about the appropriate sphere of a Public Interest Litigation are in line with well-settled PIL jurisprudence:

A PIL must espouse a public cause with real repercussions on society at large.
It is designed to correct governmental inaction where the rights of disadvantaged or diffuse groups are concerned, or to address systemic failures.
Courts have repeatedly warned against the use of PIL for personal, academic, or minor grievances.

The present judgment clearly locates the petitioner’s grievance on the latter side of this line: the choice of terminology for a department’s name—when there is no constitutional or legal injury alleged— does not rise to the level of an issue whose non-consideration would “impair the society at large”.

3.2.4. Delay and Laches in Invoking Article 226

The Court notes that the impugned order dates back to 14.12.2022, yet the challenge is mounted “after a lapse of nearly three years”. This invokes the equitable doctrine of laches:

The writ remedy is discretionary and extraordinary; it is not available to those who sleep over their rights.
Unexplained delay can, by itself, be a ground for refusal of relief, even if some technical right could otherwise be argued.

The Court links the delay to the absence of urgency, reinforcing that the issue did not warrant the exercise of extraordinary jurisdiction.

In summary, while the judgment does not spell out citations, it is evidently anchored in settled doctrines of separation of powers, limited judicial review of policy, circumscribed PIL jurisdiction, and laches.

3.3. The Court’s Legal Reasoning

3.3.1. Domain of the Executive in Naming Government Departments

The core holding is categorical:

“The naming and re-naming of government department is purely within the domain of the Government and such task cannot be undertaken by the High Court exercising writ jurisdiction under Article 226 of the Constitution of India. The courts lack the expertise in this regard and it is purely within governmental fiefdom.”

This statement does several things at once:

It characterises the choice of name as an administrative/policy decision, not a justiciable right.
It invokes institutional competence: courts are not linguists, brand strategists, or administrative planners.
It marks the boundary of judicial review by emphasising that courts cannot convert policy preferences into enforceable rights under Article 226.

Critically, the Court does not engage in a debate about which Tamil term more accurately captures “development”. It holds that this debate is not for the judiciary to resolve, but for “experts in the field to ponder on”.

3.3.2. Absence of Mala Fides, Arbitrariness, or Non-Application of Mind

The petitioner alleged that the order rejecting his proposal was vitiated by non-application of mind and administrative arbitrariness. The Court rejects these assertions, observing:

“Though a vague assertion is made that the impugned order suffers from non-application of mind and administrative arbitrariness, no whit of material is placed on record to bolster the said plea.”

Two key ideas emerge:

Burden of proof lies on the petitioner when alleging mala fides or arbitrariness. Bare allegations, without documents or concrete facts, are insufficient.
The Court, having “perceived” the actions of the authorities as “whiter than white”, sees no trigger for deeper judicial scrutiny, especially in a domain where the executive has wide discretion.

“Whiter than white” here is a rhetorical flourish meaning that the government’s decision appears legally clean, and the Court finds nothing on record to suspect illegality or improper motive.

3.3.3. Nature and Limits of Public Interest Litigation

The Court re-states what a Public Interest Litigation (PIL) is meant to do:

“A public interest litigation should espouse a cause to protect the society and to avoid a deliberate peril arising out of governmental non-concern for social good and benefit.”

Against this standard, the present case falls short. The Court notes:

The issue “is not of such gravitas that the non-consideration of the same would impair the society at large.”
The dispute is essentially about the preferred nomenclature for a department, rooted in scholarly or linguistic disagreement.
There is no demonstrated public harm or systemic failure that requires judicial correction.

Thus, the case is characterised as:

“...purely an administrative act for the experts in the field to ponder on and this court lacks expertise in this regard.”

By refusing to treat a naming dispute as a fit subject for PIL, the Court reinforces that PIL is not an all-purpose vehicle for voicing dissatisfaction with every facet of governmental functioning.

3.3.4. Delay and Lack of Urgency in Invoking Article 226

The Court treats the three-year delay as a separate and additional reason to decline relief:

“That apart, the proceedings impugned in this petition was issued way back on 14.12.2022, however, the same is put to challenge after a lapse of nearly three years. This itself shows that there is no compelling urgency involved warranting exercise of extraordinary jurisdiction under Article 226 of the Constitution of India.”

Key implications:

Article 226 is an extraordinary remedy; courts expect promptness from litigants.
Laches (inexcusable delay) undermines the credibility of any perceived urgency or public need.
If the petitioner could wait three years, the Court can reasonably infer that no pressing public injury exists.

The Court thereby embeds traditional equitable considerations into its assessment of maintainability.

3.3.5. Judicial Self-Restraint and Institutional Modesty

The judgment repeatedly emphasises judicial self-restraint:

“The courts lack the expertise in this regard…”
“The present is not a case warranting exercise of writ jurisdiction…”

The Court’s stance is that:

Even if some citizens or scholars believe the chosen term is imperfect, that does not transform their preference into a legal right enforceable in court.
The proper forum for these debates is within the executive and expert bodies (e.g., the Tamil Etymological Dictionary Project), not the courtroom.

This is an important reaffirmation that judicial review is not judicial governance.

3.4. Impact and Significance

3.4.1. On Administrative Law and Executive Discretion

The judgment strengthens the principle that courts will not micro-manage administrative choices that:

fall squarely within the executive’s policy domain,
do not infringe constitutional rights, and
are not shown to be arbitrary or mala fide.

Government nomenclature – names of departments, directorates, schemes – often reflects political choices, linguistic preferences, or cultural signalling. This decision underscores that such choices will generally be left undisturbed, barring clear illegality or discrimination.

3.4.2. On PIL Practice and Filtering of Trivial or Peripheral Causes

The Court’s insistence on “gravitas” and demonstrable societal impact for PILs contributes to an ongoing judicial effort to:

Prevent over-expansion and misuse of PIL jurisdiction.
Conserve judicial resources for cases where intervention is truly needed to protect rights or address systemic failures.
Stop the courts from becoming venues for every policy disagreement or linguistic controversy.

Future PILs that seek to:

change names of departments,
alter logos, slogans, or mottoes, or
impose preferred translations or terminology

are likely to encounter this precedent: unless a clear constitutional or legal violation and significant public impact are established, the High Court will decline to intervene.

3.4.3. On Linguistic and Cultural Questions in Constitutional Litigation

The petitioner’s central plank was linguistic – the semantic distinction between “valarchi” and “development”. The Court’s refusal to adjudicate this presents an important message:

Not every linguistic or cultural debate is suitable for constitutional litigation.
Courts will avoid being drawn into technical or scholarly disputes where no legal right is directly implicated.
Such matters are better left to policy-makers, language academies, and expert bodies.

This has a moderating effect on efforts to judicialise every aspect of cultural and linguistic policy.

3.4.4. On Future Challenges to Renaming or Non-Renaming

While the judgment is about a refusal to rename, its reasoning would also be relevant in cases where the Government chooses to rename a department, scheme, or institution, and such action is challenged solely on grounds of:

linguistic preference,
political dissatisfaction, or
symbolic disagreement,

without any concrete plea of:

discrimination,
violation of fundamental rights, or
breach of statutory or constitutional limitations.

Courts may invoke this reasoning to decline to interfere, reiterating that such decisions are generally for the executive.

4. Complex Concepts Simplified

Several legal terms and ideas appear in the judgment. The following simplified explanations may aid understanding:

4.1. Article 226 of the Constitution

Article 226 empowers High Courts to issue writs for enforcement of:

fundamental rights, and
“any other purpose” (i.e., legal rights generally).

It is a broad and powerful provision, but its use is discretionary. Courts can refuse to exercise this power when:

an adequate alternative remedy exists,
there is undue delay (laches), or
the issue is purely policy-related with no illegality or rights violation.

4.2. Writ of Certiorarified Mandamus

The petitioner sought a certiorarified mandamus, which is a composite relief:

Certiorari – to quash an order of an authority on legal grounds (e.g., lack of jurisdiction, error of law, violation of natural justice).
Mandamus – to command a public authority to perform a duty imposed by law.

“Certiorarified mandamus” thus involves:

first quashing the impugned decision (here, rejecting the renaming request), and
then directing the authority to act in a particular manner (here, to rename the department).

The Court refused both because it found no illegality to quash and no enforceable legal duty to rename.

4.3. Public Interest Litigation (PIL)

A PIL allows a person or organisation to approach the court on behalf of the public or a section thereof, even if the petitioner is not personally aggrieved, provided:

the cause involves significant public interest, and
there is a need to protect the rights or welfare of affected groups or the public at large.

PIL is not meant for:

individual grievances,
matters of personal prestige or ideology, or
trivial or academic questions without real societal impact.

4.4. Mala Fides

Mala fides means “bad faith”. A decision is mala fide if:

it is taken for a wrong or improper purpose,
it is based on personal animosity or ulterior motives, or
it is a pretext to achieve something other than what the law permits.

Courts require concrete facts to establish mala fides; mere suspicion or conjecture is not enough. In this case, the Court found no evidence of mala fides.

4.5. Arbitrariness and Non-Application of Mind

A decision is arbitrary when:

it is without rational basis,
it is whimsical or capricious, or
similar persons are treated differently without justification (offending Article 14).

Non-application of mind occurs when:

the authority fails to consider relevant factors, or
acts mechanically without genuine consideration.

The Court explicitly notes that the petitioner placed “no whit of material” to substantiate these allegations.

4.6. Laches (Delay)

Laches is an equitable doctrine. It means that if a person unreasonably delays in asserting a right, especially where such delay prejudices others or suggests lack of seriousness, a court may refuse relief even if the claim is legally arguable.

In this case, the three-year gap between the decision (14.12.2022) and the filing of the writ petition weighed against exercising Article 226 jurisdiction.

4.7. “Governmental Fiefdom”

The Court refers to naming/renaming of departments as being within “governmental fiefdom”. This is a metaphorical way to say that:

It lies within the exclusive competence and prerogative of the executive.
The judiciary has no primary role in such decisions, save to check legal/constitutional violations.

4.8. “Whiter than White”

When the Court says the authorities’ actions are “whiter than white”, it means:

the Court perceives no taint of illegality or impropriety, and
the administrative decision appears lawful and regular on its face and on the materials available.

It does not mean that the decision is necessarily the best possible one; only that it is legally unobjectionable.

5. Conclusion

The decision in Muthu Subramaniam v. State Government of Tamil Nadu is a concise yet instructive reaffirmation of key principles governing the exercise of writ and PIL jurisdiction:

Executive Domain: The naming and renaming of government departments is a matter of executive policy and administrative discretion. Courts will not, in the ordinary course, compel a particular nomenclature, especially on purely linguistic grounds.
Limited Judicial Review: In the absence of demonstrable mala fides, arbitrariness, or non-application of mind, administrative refusals to adopt preferred suggestions will not be interfered with under Article 226.
PIL Threshold: A Public Interest Litigation must raise a cause of genuine public importance, capable of affecting society at large. Debates over the semantic appropriateness of departmental names, without more, fail this test of “gravitas”.
Delay (Laches): The nearly three-year delay in challenging the impugned order was a significant factor in declining extraordinary relief, signalling that litigants must act with reasonable promptness.
Judicial Restraint and Institutional Competence: The Court explicitly acknowledges its limited expertise in areas such as linguistic policy and nomenclature, and defers to “experts in the field” and the executive, thereby reinforcing the boundary between judicial review and policy-making.

In broader terms, the judgment confirms that courts are not arenas for every policy disagreement or semantic objection. They are constitutional forums for vindicating legal and fundamental rights. Unless a clear violation of such rights or of constitutional norms is shown, particularly in matters squarely within the executive’s administrative sphere, the High Courts will exercise restraint and leave such questions to the political and administrative process.

Judicial Restraint in Administrative Nomenclature: Limits of Article 226 in Renaming Government Departments