Patna High Court - Orders
Dr. Maurya Vijay Chandra, Advocate, vs The State Of Bihar on 29 April, 2026
Author: Harish Kumar
Bench: Harish Kumar
IN THE HIGH COURT OF JUDICATURE AT PATNA
Civil Writ Jurisdiction Case No.6109 of 2022
======================================================
Dr. Maurya Vijay Chandra, Advocate
... ... Petitioner/s
Versus
The State of Bihar & Ors.
... ... Respondent/s
======================================================
Appearance :
For the Petitioner/s : Dr. Maurya Vijay Chandra ( In Person )
For the UOI : Dr. K. N. Singh, ASG
Ms. Iti Suman, CGC
For the Res. No. 7 : Mr. Alok Kumar, CGC
For the AAI : Mr. Sujeet Kumar Sinha, Adv.
For the State : Mr. Arun Kumar Bhagat, AC to AAG 12
======================================================
CORAM: HONOURABLE THE CHIEF JUSTICE
and
HONOURABLE MR. JUSTICE HARISH KUMAR
ORAL ORDER
(Per: HONOURABLE THE CHIEF JUSTICE)
27 29-04-2026Heard the petitioner, who appears in person, and the learned counsel for the State.
2. Mr. Rakesh Kumar, Joint Director, Horticulture (Administration), who appears through virtual mode, has filed an affidavit in pursuance of our order dated 27.04.2026, wherein it is stated as follows:
"11. That, in further compliance of the order dated 30.03.2026 passed by this Hon'ble Court, district-level trainings/workshops/interactions have been conducted across various districts of the State, wherein a total of 316 (three hundred sixteen) farmers have participated. The said trainings included both farmers who had earlier undergone exposure/residential training as well as other local mango growers, with the objective of ensuring wider dissemination of Patna High Court CWJC No.6109 of 2022(27) dt.29-04-2026 2/15 technical knowledge relating to scientific cultivation, post-harvest management and export readiness. The details of such district- wise programmes, along with proceedings and supporting documents, form part of the annexure series to the present affidavit.
Nu
mbe
Nature of Key technical
District / Date / r of
compliance themes /
document venue far
activity feedback
mer
s
Scientific
Workshop
planting of
conducted
mango orchards;
with mango
rejuvenation of
farmers,
Patna 18.04.2026 old orchards;
including
DHO letter Patna 52 scientific
farmers
no. 500 district maintenance;
trained at
pest-related
Centre of
information;
Excellence,
intercropping in
Basti.
mango orchards.
Innovative
Interaction
technology, post-
with
harvest
farmers
management,
18.04.2026 trained
APEDA/export
Vaishali ATMA / during
awareness,
Proceeding District Ratnagiri
50 organic
letter no. Agriculture exposure
production, drip
631 Office, visit and
irrigation,
Hajipur other
grafted plants,
progressive
windbreaks and
mango
mechanisation
farmers.
needs.
East 18.04.2026 26 Review- High-density
Champaran District / cum- planting, drip
Gyaapak Joint discussion irrigation,
no. 382 / Agriculture with grafted/clonal
Banjariya Building trained plants, organic
proceedings farmers cultivation,
and other timely
Patna High Court CWJC No.6109 of 2022(27) dt.29-04-2026 3/15 Nu mbe Nature of Key technical District / Date / r of compliance themes / document venue far activity feedback mer s mango harvesting, growers on grading, quality scientific production storage, APEDA-
and post-
linked export harvest possibilities and managemen windbreaks.
t.
Advanced mango
cultivation,
Farmer nursery
goshti with practices,
18.04.2026
Bhagalpur trained pest/disease
MadhopurB
Letter no. 29 farmers, management,
athani,
487 officials irrigation,
Sanhaula
and mango varietal
growers. selection, canopy
management and
IPM.
Scientific
Workshop orchard planting, on high-density production, practices, storage and rejuvenation, 18.04.2026 Darbhanga marketing grading/packing, Gram Letter no. 10 of mango IPM, nutrition Nikoli, 274 with management Singhwara trained including farmers compost/NPK/bo and other ron/zinc, APEDA cultivators. registration awareness.
Muzaffarpu 18.04.2026 31 District- Production, r Letter no. Joint level ripening and safe 359 Agriculture training/aw practices, Building, areness storage, Muzaffarpur initiative transport, proposed packaging, Patna High Court CWJC No.6109 of 2022(27) dt.29-04-2026 4/15 Nu mbe Nature of Key technical District / Date / r of compliance themes / document venue far activity feedback mer s marketing and scheme and awareness reported in including cold the context storage/refrigera of the ted chamber interim facilities.
order.
District- Agro-climatic level suitability for farmer mango 18.04.2026 interaction/ cultivation, Samastipur training scientific Samastipur district with local orchard Letter no. office / mango establishment, 25 422 dated district- growers; pruning/cutting 18.04.2026 level attendance of old orchards, training sheet disease and pest interaction enclosed management, with and orchard proceeding nutrient/micronu s. trient awareness.
District/blo ck-level interaction Soil testing, with mango 18.04.2026 drainage issues, growers Sheikhpura Sheikhpura and field-level Letter no. district / advisory, trained/res local farmer 20 varietal 336 dated ource interaction guidance and 18.04.2026 (with photo farmers;
farmer proceeding evidence) interaction at s and geo-
local level.
tagged photograph enclosed.
West 18.04.2026 24 Workshop Drip irrigation, Champaran Joint conducted irrigation Patna High Court CWJC No.6109 of 2022(27) dt.29-04-2026 5/15 Nu mbe Nature of Key technical District / Date / r of compliance themes / document venue far activity feedback mer s with scheduling, farmers spray schedules, earlier management of trained at fruit drop and Letter / Agriculture Centre of mango proceeding Building, Excellence, pests/diseases, no. 72 dated West Banjariya, orchard nutrition 18.04.2026 Champaran Basti (U.P.) and extension of and other such trainings to local high mango-
mango producing
growers. blocks.
High-density
Interaction planting, drip with irrigation, exposure- grafted plants, 18.04.2026 returned organic Sitamarhi Joint farmers cultivation, Proceeding Agriculture and other harvesting/gradi no. 366 Building, 30 mango ng, dated Muradpur, growers on APEDA/export 18.04.2026 Dumra,Sita production orientation, marhi and post- windbreak harvest plantation and manageme demand for nt. further local trainings.
Bhojpur Agriculture 19 District- Innovative
Letter no. Building, level technology
228 dated Bhojpur farmer intervention
18.04.2026 interaction/ cultivation and
training post-harvest
with local management of
mango mango.
growers;
attendance
sheet
Patna High Court CWJC No.6109 of 2022(27) dt.29-04-2026 6/15 Nu mbe Nature of Key technical District / Date / r of compliance themes / document venue far activity feedback mer s enclosed with proceeding s.
12. That the detailed district-wise proceedings are annexed hereto.
13. That the aforesaid activities were not merely ceremonial in nature. The trained farmers shared field-level experiences, technical inputs and practical demonstrations with other mango growers.
14. That the district reports clearly demonstrate localized dissemination, including:
scientific orchard planning and rejuvenation, canopy and nutrient management, pest and disease management including IPM, post-harvest handling, grading and storage, export awareness through APEDA, and water-use efficiency through drip irrigation.
15. That the answering respondents have also instituted a mechanism for periodic monitoring and district-level reporting, ensuring continuity of such activities and preventing the same from being one-time interventions.
16. That feedback obtained from trained farmers and other mango growers indicates:
demand for wider dissemination of training content, convergence with drip irrigation and mechanisation schemes, Patna High Court CWJC No.6109 of 2022(27) dt.29-04-2026 7/15 need for periodic farmer-to-farmer interaction, awareness on APEDA processes, and strengthening of value-chain linkages.
17. That the Directorate of Horticulture is already implementing a structured approach for capacity building and value-chain strengthening, including coordination with APEDA and other agencies.
18. That the establishment of APEDA Regional Office at Patna and approval of Integrated Irradiation-cum-Pack House at Bihta are significant steps toward enhancing export readiness.
19. That data on record shows that approximately 2235.07 metric tonnes of mangoes valued at Rs. 5.65 crores were exported from Bihar during FY 2024-25, indicating positive outcomes of ongoing interventions.
20. That the Department proposes to continue implementation of a crop-cycle aligned and value-chain based Mango Sector Plan, which includes:
farmer registry and cluster mapping, training of trainers and farmer-to- farmer extension, scientific orchard management, rejuvenation of old orchards, post-harvest management, export readiness, infrastructure convergence, and monitoring and feedback mechanisms.
Indicative
Compone Expected
Key action crop-cycle
nt outcome
timing
Farmer Update mango Year-round; Evidence-
registry farmer database; preferably based
and identify progressive before annual selection of
Patna High Court CWJC No.6109 of 2022(27) dt.29-04-2026 8/15 Indicative Compone Expected Key action crop-cycle nt outcome timing farmers, old beneficiaries cluster orchards, export- action plan and training mapping potential clusters and finalisation.
clusters.
training gaps.
Use trained farmers Multiplier Training from Ratnagiri/Basti Before major effect without of and other centres as field waiting for Trainers / local resource operations; every farmer farmer-to-
persons under district-wise to be sent farmer supervision of batches. outside the extension officers/experts. State.
Pre-flowering Training on spacing, Scientific to fruit- Improved canopy management, orchard development productivity nutrient schedule, managem stage, with and reduced irrigation, IPM and ent district losses.
disease surveillance.
variation.
Post-harvest
Identification and
and before
phased Revival of old
Rejuvenat major
rejuvenation/pruning orchards and
ion of old vegetative
of senile orchards quality
orchards flush, as
with technical improvement.
advised by
guidance.
experts.
Training on
harvesting maturity, Reduced
Immediately
Post- grading, packaging, wastage,
before and
harvest ethylene-based safe improved
during
and safe ripening, avoidance market price
harvest/marke
ripening of unsafe chemical and food
ting season.
ripening and storage safety.
practices.
Export APEDA registration Pre-harvest Increased
readiness awareness, and harvest export-
traceability, residue season; compatible
management, repeated produce and
Patna High Court CWJC No.6109 of 2022(27) dt.29-04-2026 9/15 Indicative Compone Expected Key action crop-cycle nt outcome timing buyer/exporter farmer access interface and linkage annually. to premium with pack-house markets.
facilities.
Pursue approval/operational isation of Bihta Pack Project-
House/Irradiation
Infrastruc based;
facility; promote End-to-end
ture aligned with
cold-chain, pack- value-chain
convergen regulatory
house, strengthening.
ce approvals and
reefer/transport and
budget.
ripening
infrastructure under
eligible schemes.
District-wise
Accountable
proceedings,
implementatio
Monitorin photographs, farmer Quarterly/sea
n without day-
g and feedback, and sonal
to-day
feedback outcome tracking reporting.
micromanage
after each major
ment.
training block.
xxx xxx xxx
22. That it is respectfully submitted that interventions in the mango sector are technical, seasonal and crop-cycle dependent, and yield optimal results only when synchronised with agronomic timelines.
23. That certain technical activities such as pruning, rejuvenation, post-harvest management and exposure visits cannot be effectively undertaken at short notice, and require alignment with field conditions and crop stages.
24. That while the answering respondents remain fully guided by directions of this Patna High Court CWJC No.6109 of 2022(27) dt.29-04-2026 10/15 Hon'ble Court, it is submitted that operational aspects such as scheduling, batching, technical content and implementation modalities are best determined administratively in consultation with domain experts.
25. That it is a settled principle that policy choices and technical/administrative matters fall within the executive domain, subject to limited judicial review.
Reliance is placed on:
State of Punjab v. Ram LubhayaBagga, (1998) 4 SCC 117 BALCO Employees' Union v. Union of India, (2002) 2 SCC 333 Aravali Golf Club v. Chander Hass, (2008) 1 SCC 683 Census Commissioner v. R. Krishnamurthy, (2015) 2 SCC 796
26. That it is further submitted that judicial review does not extend to micromanagement of administrative or technical execution, so long as actions are bona fide and within the framework of law.
27. That it is further respectfully submitted that the present writ proceeding does not partake the character of a bona fide Public Interest Litigation, but is essentially founded on matters of individual/personal interest, as is evident from the material placed on record by the petitioner himself. In this regard, reference is invited to the social media post (Twitter/X) relied upon in the earlier Supplementary Counter Affidavit bearing Oath No. 39559 dated 24.04.2025, annexed as Annexure R/10, which reflects personal achievements and private commercial/export activities relating to mango produce. The reliance on such material demonstrates that the issues raised are not in the nature of public injury or systemic failure warranting PIL intervention, but are intrinsically linked to the petitioner's personal interests."
Patna High Court CWJC No.6109 of 2022(27) dt.29-04-2026 11/15
3. In paragraph-27 of the affidavit dated 28.04.2026 it is mentioned that the present writ proceeding does not partake the character of a bona fide Public Interest Litigation and it is essentially founded on matters of individual/personal interest. It is further mentioned in paragraph-26 that the judicial review does not extend to micromanagement of administrative or technical execution, so long as actions are bona fide and within the framework of law.
4. Needless to say that when the matter was taken up on 30.03.2026, after going through the supplementary counter affidavit filed by the Deputy General Manager, A.P.E.D.A. as well as the supplementary counter affidavit filed by Rakesh Kumar, Joint Director, Horticulture (Administration), we came to hold as follows:
"3. From Annexure-D, which is attached to the supplementary counter affidavit of respondent no. 3 and 4 dated 19.03.2026, we found the list of 32 farmers from six districts i.e. Patna, Muzaffarpur, West Champaran, Darbhanga, Sitamarhi and Bhagalpur, who were deputed for residential training at the Centre of Excellence, Basti, Uttar Pradesh, for a period of 7 days in January 2026.
4. Mangoes hold a special place in the fruit world. It is a climacteric fruit and continues to ripe rapidly even after harvest. A farmer carefully harvests hundreds of ripe and flagrant mangoes from his orchard. Within days, many of those beautiful fruits get softened beyond selling, Patna High Court CWJC No.6109 of 2022(27) dt.29-04-2026 12/15 develop dark spots or simply lose its appeal. Understanding how to properly store these delicious fruits is not just about keeping them fresh longer, rather it is about ensuring that farmers get their returns while consumers enjoy quality produce and precious fruit does not go to waste. After harvesting, mangoes are in a constant state of change. The moment a mango leaves the tree, a complex series of biochemical reactions kicks into high gear. The mangoes are vulnerable to fungal diseases, mechanical damage during transport and moisture loss that leaves them shrivelled and unappealing.
5. It is crucial to understand that different varieties of mangoes have different temperature tolerance. The mango farmers do not give required attention and care in using requisite inputs and adopting improved quality practises in their mango orchards, except using some insecticides to protect the mangoes from insects. Most of the farmers lack technical knowledge and training in development of commercial mango orchards. Non-availability of expert technical guidance to the farmers in addressing the production related issues is required to be addressed.
6. It is the duty of the Department of Horticulture to organize a series of training programmes for the farmers in the districts on natural methods of ripening mango. The consumption of mangoes ripened with calcium carbide causes health problems, like cancer, insomnia and loss of appetite. By combining traditional farmer knowledge with modern organized method, the mango farmers can earn more while keeping the farms healthy for a long term.
7. Learned counsel appearing for the respondent no. 7 has furnished a list containing the names of registered mango farmers in the State of Bihar, which are 398 in number. He has furnished another list containing the names of the exporters, which are taken on record.
8. After going through the list of mango Patna High Court CWJC No.6109 of 2022(27) dt.29-04-2026 13/15 farmers in the district of West Champaran, we find that although there are 176 registered mango farmers in the district, only five farmers of that particular district were sent for training in the month of January 2026, as reflected in Annexure- D to the supplementary counter affidavit filed on behalf of respondent no. 3. There is nothing in the affidavit to indicate the nature of the training imparted to such farmers or how the said training has been utilized by those farmers or the authorities concerned for the benefit of other mango farmers who were not sent for training. It is expected that the concerned authorities shall interact with the farmers from different districts of the State of Bihar who have already undergone training in different phases, as reflected in the counter affidavit, obtain their feedback, and in their presence, interact with other mango farmers who have not undergone such training, either physically or virtually. A suitable venue, preferably Anganbadi Centre or any other appropriate place, shall be selected for such training purpose expeditiously and the specified date and time shall be communicated to the Mango farmers well in advance.
Details of the training imparted to the Mango farmers in the State of Bihar shall be placed before this Court by way of a specific affidavit to be filed by the Joint Director, Horticulture, by the next date, with a copy thereof served upon the learned counsel for the petitioner. The State may also take initiative to engage scholars from research institutes across different States to impart professional training on mango cultivation and its protection.
9. Needless to say, the export of Mangoes is a significant driver of financial benefits to a large number of Mango farmers, offering substantial economic returns, fostering rural development, therefore, proper preservation is essential before taking steps for export. This is precisely why adequate training in production and preservation for mango farmers is necessary in this regard."
Patna High Court CWJC No.6109 of 2022(27) dt.29-04-2026 14/15
5. The purpose of passing such an order is to see that other framers who have not undergone training and the State has not taken any steps to train them for proper harvesting and preservation of the mangoes to be benefitted, inasmuch as there are 398 registered mango farmers in the State of Bihar and in the district of West Champaran 176 registered mango farmers; only five farmers of that particular district had been sent for training in the month of January, 2026. While passing such order, we made it clear that the authorities shall interact with the framers from different districts of the State of Bihar, who have already undergone the training in different phases, obtain their feedback, and in their presence, interact with other mango farmers, who have not undergone such training, either physically or virtually. A suitable venue, preferably Anganbadi Centre or any other appropriate place, fixing specified date and time and also take initiative to engage scholars from research institutes across different States to impart professional training on mango cultivation and its protection. Since the export of Mangoes is a significant driver of financial benefits to a large number of Mango farmers, offering substantial economic returns, fostering rural development and therefore, we feel it necessary that proper preservation is very much essential before Patna High Court CWJC No.6109 of 2022(27) dt.29-04-2026 15/15 taking steps for export and that is why the adequate training in production and preservation of mango is very much necessary.
6. Mr. Rakesh Kumar, Joint Director, Horticulture (Administration) shall appear in person on 1st May, 2026 at 10:30 A.M. and apprise this Court as to why he has taken a stand that this matter does not come within the purview of Public Interest Litigation and it amounts to interference in technical aspect and this is a litigation which is essentially of individual/personal interest, once this Court having considering the significance of the matter has directed it to be a Public Interest Litigation.
7. List this matter on 01.05.2026.
8. A free copy of the order be handed over to the learned Advocate General.
(Sangam Kumar Sahoo, CJ) ( Harish Kumar, J) Anjani/-
U