Paragraph numbers below are the court’s original numbering, recovered from the source text.
39. A cumulative reading of the aforementioned decisions makes it evident that, in the context of petitions under Article 32, the doctrine of laches operates as a flexible rule of practice rather than a rigid rule of law 98 to be mechanically applied. Its application is anchored in sound judicial discretion, moulded by the specific facts and circumstances of each case. This discretionary approach empowers the Court to perform a crucial balancing exercise by weighing the equity in not allowing stale claims against its paramount constitutional duty to enforce fundamental rights.
40. Furthermore, a conspectus of the above decisions demonstrates that whenever this Court has been called upon to apply the doctrine of laches, its inquiry has consistently been guided by three primary considerations: first, whether there has been an inordinate delay in approaching the Court; secondly, whether the petitioner has provided a cogent and satisfactory explanation for such delay; and thirdly, whether entertaining the belated claim would unsettle settled matters and prejudice third party rights by reopening matters long concluded.
41. It is important to clarify and emphasise that, when applying the doctrine of delay and laches, consideration should be given to the totality of the circumstances affecting both parties, rather than the mere fact of delay. As has been rightly held, the test is not as to the physical running of time.1 To apply the doctrine strictly based on the quantum of delay would fundamentally alter its core character, transforming it from a flexible, discretionary standard into a rigid rule. Such an approach would effectively convert the equitable doctrine into a rule of statutory limitation, a position contrary to the spirit of this Court’s decisions on this issue.
42. When evaluating the totality of circumstances for applying the doctrine of delay and laches to an Article 32 petition, the pivotal considerations, as delineated above, are twofold: (i) whether entertaining the claim would unsettle concluded matters and prejudice third-party rights, and (ii) whether the petitioner has offered a cogent explanation for the delay. At this juncture, it is crucial to appreciate the interplay between these two factors. Frequently, when a party approaches this Court after a considerable hiatus, adjudicating the claim and granting the relief sought will inevitably unsettle, to some extent, existing arrangements and potentially impact third-party rights. See ¶ 13, M/s Dehri Rotas Light Railway Company Limited v. District Board Bhojpur & Ors. (1992) 2 SCC 598. [2026] 4 S.C.R. Mizo Chief Council Mizoram, Thr, President Shri L. Chinzah v. Union of India & Ors.
43. If a rigidly conservative approach were adopted, the mere prospect of such disruption or unsettling of third-party rights would invariably lead to the dismissal of the petition at the threshold. Further, where the delay has been satisfactorily explained, demonstrating an absence of blameworthy conduct or negligence on the part of the petitioner, barring them from pursuing their fundamental rights at the threshold stage on the basis that it will affect third parties would be manifestly unjust, especially in the context of proceedings under Article 32.
44. It is a well-settled proposition that the jurisdiction of this Court under Article 32 is expansive and is not confined to the issuance of traditional prerogative writs, but explicitly encompasses the power to issue any directions, orders, or writs appropriate for the enforcement of fundamental rights.2 This Court has repeatedly affirmed its constitutional mandate to develop new tools and devise innovative remedies to facilitate the enforcement of fundamental rights.3 Consequently, the mere possibility of the potential disruption that such relief might cause cannot serve as the sole bedrock for dismissing a petition at the threshold on the ground of laches. Where a petitioner furnishes a cogent explanation for the delay, the court is bound to examine the matter. If the court subsequently determines that the specific relief claimed is unfeasible or would unduly prejudice third-party rights, it would exercise its plenary powers to mould the relief in such a manner that disruption is minimised whilst still ensuring that the fundamental rights of the petitioner are enforced.
45. Flowing from the aforesaid discussion, it is evident that the adequacy of the explanation for the delay constitutes the paramount consideration when determining whether an Article 32 petition ought to be dismissed on the ground of laches. Stated differently, the operative test is not one of ‘unreasonable delay’ but of ‘unexplained delay’. This principle is fortified by the fact that, even in instances where this Court has declined relief to prevent the disruption of crystallised third-party rights, such as in Aflatoon (supra) and others4, the foundational premise for dismissal was a petitioner’s failure to furnish a cogent and satisfactory explanation for the delay. See ¶ 14, Rashid Ahmed v. Municipal Board, Kairana, 1950 SCC OnLine SC 16. See ¶ 20, Nilabati Behera v. State of Orissa & Ors. (1993) 2 SCC 746 & ¶ 13, Bandhua Mukti Morcha v. Union of India (1984) 3 SCC 161. See ¶ 30, R.S. Makashi v. I.M. Menon (1982) 1 SCC 379 & ¶ 23-25, S.S. Moghe v. Union of India (1981) 3 SCC 271. 100
46. This emphasis on the unexplained delay assumes a heightened significance in writ proceedings where the State is the respondent. Situations frequently arise, like in G.P. Doval (supra), where the delay in invoking Article 32 is at least in part attributable to the State’s own conduct, such as prolonged administrative indecision or inertia. In such scenarios, the State cannot be permitted to benefit from its own lethargy by weaponising the doctrine of laches against a petitioner, particularly when it itself has delayed taking a conclusive decision until matters had already attained artificial finality.5
47. The evolution of this Court’s application and reliance on the doctrine of laches suggests that the apprehensions articulated by Hegde, J., in his dissenting opinion in Tilokchand (supra) are, to a large extent, allayed. The Court has consistently held that the doctrine of laches should not be applied rigidly and that delay and laches cannot be valid defences in cases where circumstances exist which shock the judicial conscience of the Court or where the demand for justice is so compelling that a constitutional court ought to exercise its jurisdiction with a view to promoting justice. 6 Where the circumstances demanded, this Court has proceeded on the notion that there is no “limitation” to doing justice and that the need for finality must be balanced with the need to rectify injustice.7 Further, as observed in the decision in G.P. Doval (supra), this Court is not tethered to a purely technical approach to delay. It recognises that a petitioner’s inability to approach the court on time may be caused by genuine systemic and practical hardships, rather than mere negligence.
48. The exposition by this Court in Assam Sanmilita Mahasangha (supra) and Section 6A – In Re (supra) further adds a new dimension to the issue of delay and laches in Article 32 petitions. By invoking the aspect of ‘public interest’, the Court has ensured that important public issues are not held to be beyond the purview of this court’s jurisdiction solely on the basis of the fact that there was a delay in bringing the same before the court. Further, by invoking the idea of transformative constitutionalism, the Court has upheld the view that the Constitution is a social document, whose principles and See ¶ 17, Sukh Dutt Ratra & Anr. v. State of Himachal Pradesh & Ors. (2022) 7 SCC 508. See ¶ 12.12 & 12.13, Vidya Devi v. State of Himachal Pradesh & Ors. (2020) 2 SCC 569 See ¶ 18, Sukh Dutt Ratra & Anr v. State of Himachal Pradesh & Ors. (2022) 7 SCC 508 & ¶ 51, Urban Improvement Trust v. Vidhya Devi & Ors., 2024 SCC OnLine SC 3725. [2026] 4 S.C.R. Mizo Chief Council Mizoram, Thr, President Shri L. Chinzah v. Union of India & Ors. ideals ought to be appreciated and applied dynamically, in line with the changing tides of society. Consequently, delay and laches may not be relevant factors where it is shown that an issue needs to be constitutionally reevaluated owing to the change in circumstances that has ensued.
49. Another crucial facet of transformative constitutionalism, as heralded by this Court in Navtej Singh Johar & Ors v. Union of India, reported in (2018) 10 SCC 1, and Indian Young Lawyers Association & Ors v. State of Kerala & Ors, reported in (2019) 11 SCC 1, is the Constitution’s profound potential to address and correct historical wrongs. Historical injustices are often deeply entrenched in societal structures and arrangements, rendering them self-perpetuating across generations. Correcting such historical injustices forms the fulcrum of the Constitution, specifically Part III, which deals with fundamental rights. The emancipatory power of the Constitution lies precisely in its capacity to break these cycles. It requires constitutional provisions to be interpreted and applied in a manner that actively seeks to rectify these entrenched systemic inequities.
50. In this context, a rigid or mechanical application of the doctrine of delay and laches could inadvertently serve to perpetuate historical wrongs, effectively denying access to justice and shielding systemic inequities behind procedural barriers. However, as our preceding analysis demonstrates, this Court’s jurisprudence is sufficiently robust to prevent such an outcome. The flexible, context-specific approach to laches ensures that the historical realities and practical impediments faced by litigants are duly accounted for. Consequently, any attempt to invoke delay as a procedural shield to insulate historical injustices from judicial scrutiny would likely fail.
51. When this Court is confronted with claims that are inextricably linked to notions of historical wrong or systemic injustice, the judicial scales must largely tilt in favour of granting access to the court. The ultimate adjudication on the merits may or may not find the substantive law to be in favour of a petitioner. However, the very act of allowing these claims to be heard and deliberated upon is an essential aspect of constitutional recognition. It ensures that the procedural threshold of laches does not become an insurmountable wall.
52. Such ideals of constitutionalism are further enabled by Article 32, which imposes a duty and a privilege on this Court to enforce 102 fundamental rights enshrined in the Constitution. At this juncture, it is apposite to refer to the following observation made by this Court in Daryao & Ors v. State of U.P. & Ors., reported in 1961 SCC OnLine SC 21: “8. There can be no doubt that the fundamental right guaranteed by Article 32(1) is a very important safeguard for the protection of the fundamental rights of the citizens, and as a result of the said guarantee this Court has been entrusted with the solemn task of upholding the fundamental rights of the citizens of this country. The fundamental rights are intended not only to protect individual’s rights but they are based on high public policy. Liberty of the individual and the protection of his fundamental rights are the very essence of the democratic way of life adopted by the Constitution, and it is the privilege and the duty of this Court to uphold those rights. This Court would naturally refuse to circumscribe them or to curtail them except as provided by the Constitution itself. It is because of this aspect of the matter that in Romesh Thappar v. State of Madras in the very first year after the Constitution came into force, this Court rejected a preliminary objection raised against the competence of a petition filed under Article 32 on the ground that as a matter of orderly procedure the petitioner should first have resorted to the High Court under Article 226, and observed that “this Court is thus constituted the protector and guarantor of the fundamental rights, and it cannot, consistently with the responsibility so laid upon it, refuse to entertain applications seeking protection against infringements of such rights”. […]” (Emphasis Supplied)
53. On similar lines, this Court in Prem Chand Garg & Anr v. The Excise Commissioner, U.P & Ors, reported in 1962 SCC OnLine SC 37, observed as follows: “2. […]The fundamental right to move this Court can, therefore, be appropriately described as the corner-stone of the democratic edifice raised by the Constitution. That is why it is natural that this Court should, in the words [2026] 4 S.C.R. Mizo Chief Council Mizoram, Thr, President Shri L. Chinzah v. Union of India & Ors. of Patanjali Sastri J., regard itself “as the protector and guarantor of fundamental rights,” and should declare that “it cannot, consistently with the responsibility laid upon it, refuse to entertain applications seeking protection against infringements of such rights.” In discharging the duties assigned to it, this Court has to play the role “of a sentinel on the qui vive” and it must always regard it as its solemn duty to protect the said fundamental rights’ zealously and vigilantly. […]” (Emphasis Supplied)
54. The overarching discourse on the doctrine of delay and laches becomes crystal clear when situated within the broader context of this Court’s constitutional duty and privilege under Article 32, as clearly enunciated in Daryao (supra) and Prem Chand (supra). This Court has consciously evolved the equitable doctrine of laches to ensure that it in no manner circumscribes or dilutes the solemn constitutional responsibility vested in it. A strict, mechanical application of delay would invariably lead to the dismissal of petitions at the very threshold, precluding any substantive adjudication of the fundamental rights claims advanced. Such an approach would be fundamentally antithetical to this Court’s role as the protector and guarantor of fundamental rights and would effectively shrink the profound duty and privilege entrusted to this Court. (c) Application to the facts of this matter
55. Adverting to the factual matrix of the present case, a prima facie assessment might suggest that the present writ petition is barred by the doctrine of laches. Undeniably, there has been an inordinate delay of nearly six decades, given that the impugned notification was issued in the year 1955 and the present petition was instituted only in the year 2014. Furthermore, adjudicating the claims raised herein would inevitably necessitate reopening historical legal settlements that have long attained finality. However, as delineated in the preceding analysis, the mere quantum of delay or the prospect of disruption cannot be considered as sufficient reasons in themselves to bar a petition under Article 32. What is important is to gauge if the petitioner has a cogent explanation for the delay. 104
56. It stands to reason that an inordinate delay spanning six decades is rarely attributable to a solitary cause. The present factual matrix is no exception. To explain its prolonged absence from this Court, the petitioner has placed reliance on a confluence of mitigating circumstances.
57. One mitigating factor is the region’s unique and tumultuous historical trajectory. In the decades immediately following Independence, the administrative and constitutional status of the area was in a state of continuous evolution. Originally administered as the Lushai Hills district within the State of Assam, the region was subsequently reorganised into the Union Territory of Mizoram under the North- Eastern Areas (Reorganisation) Act, 1971, before finally attaining full statehood in 1987. This period was simultaneously marked by significant political upheaval spanning nearly two decades in the form of an insurgency. Viewed cumulatively, these background conditions would have presented formidable practical hurdles. In such a climate of acute political unrest and chaos, claims for compensation and historical land rights are inevitably relegated to the periphery, making it exceptionally difficult for Mizo Chiefs to secure meaningful engagement with their grievances, especially within political circles.
58. Another mitigating circumstance is the Mizo Chiefs’ continuous agitation of their claims before various forums. The material on record evidences a pursuit of their grievances, thereby dispelling the notion that the chiefs were indolent or slumbering over their rights. We are, however, mindful that the mere filing of successive representations to the authorities, particularly after previous representations have been rejected or a reasonable period has elapsed, does not furnish a valid explanation to surmount the bar of laches.8
59. In the present factual matrix, while it might be contended that the chiefs persisted with administrative representations for a prolonged duration, a crucial factor warrants specific attention. On multiple occasions, respondent no. 2 (the State of Mizoram) conducted itself in a manner that engendered a legitimate expectation amongst the See ¶ 5-7, State of Orissa v. Pyarimohan Samantaray & Ors. (1977) 3 SCC 396 & ¶ 6-10 & Karnataka Power Corpn. Ltd. v. K. Thangappan (2006) 4 SCC 322. [2026] 4 S.C.R. Mizo Chief Council Mizoram, Thr, President Shri L. Chinzah v. Union of India & Ors. chiefs that an amicable resolution was imminent, thereby obviating the immediate need for adversarial litigation. Evidence of such conduct is reflected in the official assurances tendered by the State before the Gauhati High Court, at a time when the chiefs were actively agitating for their rights. To substantiate, it would do well to look at the circumstances in which the writ appeals being pursued by the chiefs in the Gauhati High Court came to be disposed of: a. In Writ Appeal No. 69 of 1998, the Counsel for the State of Mizoram submitted that the government is considering the claim for compensation and that a suitable order would be passed shortly, in consultation with the Union of India. In lieu of this statement, the counsel for the chiefs did not press the issue further. Consequently, the High Court disposed of the matter with the observation and direction that the government of Mizoram would consider the claim of the village chief, in consultation with the Union of India, expeditiously and preferably within three months. If the chiefs were not satisfied with the order, they were entitled to seek redressal of their grievances before an appropriate forum b. Thereafter, in Writ Appeal No. 598 of 2005, once again, the Counsel for the State of Mizoram stated that the claim as espoused by the chiefs would be adjudicated afresh by the State in accordance with law. Consequently, the High Court closed the writ appeal with the direction to the government of Mizoram to consider the claim of the chiefs afresh. In the event the chiefs felt aggrieved by the decision taken by the government of Mizoram, it was left open for them to pursue such remedy as may be available under law.
60. Further fortifying this expectation is the fact that the Chief Minister of Mizoram, on at least two distinct occasions, addressed formal communications to the Prime Minister of India, espousing the chiefs’ claims for compensation. It is necessary to clarify that this Court does not construe such intergovernmental correspondence as constituting promissory estoppel against the State, being acutely aware that political communications often carry dimensions beyond the purview of judicial consideration. Nevertheless, these communications are pertinent to the extent that they signalled a sympathetic stance towards the chiefs’ grievances. Such conduct could reasonably have 106 led the chiefs to hope that a resolution was forthcoming, thereby dissuading them from initiating litigation.9
61. Weighing the totality of these circumstances, this Court is conscious of the fact that the delay herein is undeniably inordinate, and the explanation offered by the petitioner is, strictly speaking, not unequivocally convincing. Nevertheless, we are not inclined to dismiss this petition at the threshold solely on the ground of delay. It is evident from the record that the State of Mizoram (respondent no.2) has held out hope for an amicable settlement and never outrightly rejected the grievances of the chiefs. It is this unique combination, the continuous representations made by the chiefs coupled with the State’s supportive stance, that understandably pushed the chiefs to seek an administrative resolution rather than immediately pursuing legal remedies. Equally significant is that, on two prior occasions when the chiefs approached the High Court, the matter was not adjudicated on the merits. Instead, owing to the ongoing dialogue between the parties, the High Court left the avenue open for the chiefs to pursue appropriate legal remedies in the future. To shut the doors on them at this third instance, without ever examining the substance of their claims, would be highly unjust. (II) Whether any fundamental rights of the Mizo Chiefs were violated?
62. It is well settled that, for relief to be granted in a writ petition under Article 32, a case must be made out establishing the existence of a fundamental right and its breach, actual or threatened.
63. Right to property was earlier enshrined in Articles 19(1)(f) and 31 of the Constitution. It may be noted that both these provisions were repealed by the Constitution (Forty-Fourth Amendment) Act, 1978. However, the 44th Amendment is prospective in its operation, and all laws passed and executive action taken prior to 20th June 1979 will continue to be judged by and be subject to the provisions of Part III, including Articles 19(1)(f) and 31.
64. Article 19(1)(f) guaranteed to the Indian citizens a right to acquire, hold, and dispose of property. Article 19(5), however, permitted the See ¶ 21, P.C. Sethi v. Union of India (1975) 4 SCC 67 & ¶ 16, Purshottam Lal v. Union of India (1973) 1 SCC 651. [2026] 4 S.C.R. Mizo Chief Council Mizoram, Thr, President Shri L. Chinzah v. Union of India & Ors. State to impose by law reasonable restrictions on this right in the interests of the general public or for the protection of the interests of any Scheduled Tribe. Article 31(1) laid down that no person could be deprived of his property without the authority of law. Article 31(2), on the other hand, underwent significant change and was the focal point of multiple constitutional amendments. Article 31(2) as it stood when it was originally enacted and Article 31(2) as it stood before its abrogation in 1978, are reproduced below: “Article 31(2) at the time of enactment of the Indian Constitution No property, movable or immovable, including any interest in, or in any company owning, any commercial or industrial undertaking, shall be taken possession of or acquired for public purposes under any law authorising the taking of such possession or such acquisition, unless the law provides for compensation for the property taken possession of or acquired and either fixes the amount of the compensation, or specifies the principles on which, and the manner in which, the compensation is to be determined and given. Article 31(2) as it stood before its abrogation in 1978 No property shall be compulsorily acquired or requisitioned save for a public purpose and save by authority of a law which provides for acquisition or requisitioning of the property for an amount which may be fixed by such law or which may be determined in accordance with such principles and given in such manner as may be specified in such law, and no such law shall be called in question in any court on the ground that the amount so fixed or determined is not adequate or that the whole or any part of such amount is to be given otherwise than in cash.”
65. In the present case, the central dispute concerns the alleged violation of the Mizo Chiefs’ right to property, as guaranteed under Articles 19(1)(f) and 31 of the Constitution, respectively. The petitioner claims this right was breached either because the Mizo Chiefs were deprived 108 of their lands without lawful authority, or because the compensation paid to them was wholly ‘illusory’. Given that the impugned actions of the respondents occurred at a time when the right to property was a fundamental right under Part III, and considering that the Constitution (Forty-fourth Amendment) Act, 1978, operates only prospectively, the right to property was firmly in existence at the relevant time. Consequently, the existence of a fundamental right, as is required for invoking and claiming relief under Article 32, stands satisfied.
66. It is established that who bears the burden of proof in cases where fundamental rights violations are alleged depends on the fundamental right alleged to have been violated. The same burden of proof rule will not apply to all fundamental rights violation challenges.10 However, in cases such as the present one, the initial burden is on the petitioner to satisfy the Court and make out a case for an invasion of their fundamental right(s).11
67. To discharge this initial burden and successfully establish a violation of their fundamental right to property, the petitioner must necessarily succeed on two distinct fronts. First and foremost, it must prove a clear title of the Mizo Chiefs over the subject lands, which, in the context of its sweeping claim, effectively encompasses the entire territorial expanse of the present-day State of Mizoram.12 To establish such a title, the petitioner must conclusively demonstrate that, under the chieftainship system, as it operated during the British regime, the Mizo Chiefs held complete ownership of the land, rather than merely functioning as local administrative heads. Secondly, and only upon proving the ownership as aforesaid, the petitioner must satisfy the other parameters under Article 31. This includes, amongst other things, proving that the respondents deprived the chiefs of their property without lawful authority, or that the property was acquired without providing due compensation.
68. In an effort to discharge the burden of establishing title to the land, the petitioners have primarily relied on accounts and writings of scholars and officials of the British government. Upon a meticulous See ¶ 15-29, Deena & Ors. v. Union of India (1983) 4 SCC 645. See ¶ 5, A. Hamsaveni & Ors. v. State of Tamil Nadu & Anr. (1994) 6 SCC 51. See ¶ 4, Bokaro and Ramgur Ltd. v. State of Bihar, 1962 SCC OnLine SC 379. [2026] 4 S.C.R. Mizo Chief Council Mizoram, Thr, President Shri L. Chinzah v. Union of India & Ors. perusal of the said material, it is, at the very outset, highly ambiguous whether these texts unequivocally recognise the Mizo Chiefs as the absolute owners of the land. Furthermore, even assuming that such an interpretation could be culled from these writings, the petitioners have advanced no compelling justification as to why such writings and accounts should be elevated to the status of conclusive evidentiary proof. It is legally untenable for this Court to rest a decision of such magnitude on the fragile foundation of such flimsy submissions and woefully inadequate proof.
69. The material adduced by the respondent, at least on a prima facie examination, indicates that during the British administration of the Lushai Hills district, the title over the land never vested in the Chiefs. Furthermore, the record before us is bereft of any comprehensive compilation or analysis of the boundary papers issued to the Chiefs, nor is it established that these documents were uniform in their conferment of rights and duties. However, an examination of the boundary paper available on record entirely belies the petitioner’s claim, as nothing therein even remotely suggests the conferment or recognition of absolute ownership of land. Consequently, we are constrained to hold that the petitioners have woefully failed to discharge their burden of proving title over the subject lands.
70. We are cognisant that, unlike in modern times, establishing land title from the pre-independence era, especially within a traditional chieftainship system, rarely involves a neat or conclusive paper trail. However, given the sheer magnitude of the petitioner’s claims, it is only reasonable to expect a much deeper historical investigation on its part. To substantiate such an extravagant demand, the petitioner ought to have relied on alternative sources of evidence, such as government documents, official notifications, and administrative orders, to build a coherent understanding of their alleged title. Both sides have failed to present a continuous, documented chain of events that would clearly map out the status of the land at different periods.
71. Furthermore, the constitutional jurisprudence governing the right to property, particularly under the erstwhile Article 31, is deeply intricate and has been the subject of extensive judicial exposition. Consequently, apart from establishing ownership, there are other 110 aspects to the right to property that the petitioner had to prove thoroughly. For instance, while the petitioner baldly asserts that the statutory compensation disbursed to the Mizo Chiefs was ‘illusory’, they have entirely failed to traverse the plethora of legal precedents rendered by this Court that delineate the parameters for determining when compensation becomes legally illusory. Moreover, the pleadings are silent on how this specific claim interacts with the broader constitutional framework of property rights under Part III, or on how it reconciles with other legislation in force in the then State of Assam. In essence, the petitioner has approached a profoundly complex legal issue in a simplistic and superficial manner.
72. The petitioner has further advanced a plea of discrimination, contending that the Mizo Chiefs stood on an equal historical footing with the rulers of the erstwhile Princely States. They argue that the State’s failure to grant them comparable compensation or privy purses is manifestly arbitrary and violative of their fundamental rights. However, this assertion, much like its above claims, is entirely devoid of any legal basis and thereby merits outright rejection. The privy purses and other privileges granted to the erstwhile rulers of the Princely States were the direct outcome of specific, pre-constitutional political and contractual arrangements negotiated between those rulers and the Government. Consequently, it would be legally flawed to equate and elevate these entitlements to the status of a right, which all erstwhile rulers were constitutionally bestowed upon. Such political arrangements cannot be claimed as a matter of a legally enforceable right, much less a fundamental right.
73. The petitioner has also contended that the State of Assam (the parent State in 1954) lacked legislative jurisdiction to enact the Act, 1954. However, as the petitioner has not discharged its burden of establishing any violation of the fundamental rights of the chiefs, we do not deem it necessary to address the vires of the Act, 1954 or the legality of the impugned notification in this present writ petition.
74. Therefore, having considered the matter from all vantage points, the inescapable conclusion is that the petitioner has not been able to establish any violation of the fundamental rights of the Mizo Chiefs in the present matter. Consequently, the petitioner is not entitled to any of the reliefs sought herein. [2026] 4 S.C.R. Mizo Chief Council Mizoram, Thr, President Shri L. Chinzah v. Union of India & Ors.
75. For all the foregoing reasons, this writ petition is accordingly dismissed.
76. Pending applications, if any, shall also stand dismissed. Result of the case: Writ Petition Dismissed. †Headnotes prepared by: Ankit Gyan