K. Purushottam Reddy vs Union of India and Ors.

3. The delimitation process is, by design, a legislative and executive function – If this Court were to compel such an exercise through judicial fiat, it would likely be construed as an interference in the policy-making prerogative of the Executive – The constitutional edifice carefully balances institutional roles, and any disruption of that equilibrium would undermine both the legitimacy and functional integrity of the democratic process. [Para 21]

4. The constitutional mandate u/Art.170(3) of the Constitution serves as a bar on any delimitation exercise concerning the States of Andhra Pradesh and Telangana, or any other State – The demand for immediate delimitation in Andhra Pradesh and Telangana runs contrary to both the letter and spirit of the constitutional design – The challenge, therefore, fails to establish any legally sustainable ground for intervention by this Court. [Para 22] Constitution of India – Arts.14, 170 – Andhra Pradesh Reorganisation Act, 2014 – s.26 – Notification Nos. SO No. 1015(E) dated 06.03.2020 and SO 1023(E) dated 03.03.2021 – Whether the failure of the Union of India to give effect s.26 of the AP Reorganisation Act has frustrated the legitimate expectation of the electorates of the States of Andhra Pradesh and Telangana:

Held: 1. It is trite law that the doctrine of legitimate expectation, while forming an integral part of the jurisprudence on fairness in administrative action, does not clothe a party with an enforceable right in itself – It operates within the bounds of legality and must necessarily conform to constitutional and statutory mandates. [Para 35]

2. In the present case, any expectation arising from the text of s.26 of the AP Reorganisation Act cannot be viewed in isolation, but must be read in conjunction with the clear caveat engrafted in its opening phrase—“subject to the provisions contained in Art.170 of the Constitution” – Once the applicability of Art.170(3) is established, which constitutionally defers the delimitation exercise until after the publication of the relevant figures of the 2026 census, any contrary expectation stands eclipsed by this express constitutional limitation. [Para 36]

3. Thus, while the sentiment underlying the claim of the Petitioner(s) may not be without foundation—particularly given the passage of over a decade since the enactment of the AP Reorganisation Act— the legal threshold for invoking the doctrine of legitimate expectation has not been met – The Petitioner(s) cannot, in law, claim a right to delimitation in defiance of a constitutional mandate, nor can they invoke administrative fairness to defeat a clear constitutional prescription. [Para 37]

Doctrines/Principles – Doctrine of legitimate expectation: Held: The doctrine of legitimate expectation is a well-recognised principle in administrative law, rooted in the ideals of fairness, non-arbitrariness, and transparency in executive action – It arises when a public authority, either through a consistent past practice, an express promise, or a statutory policy, creates an expectation in the mind of an individual or class of persons that a certain course of action will be followed – While such expectation does not amount to a legal right in the strict sense, courts have consistently held that it may nonetheless warrant judicial protection where its denial results in manifest unfairness or arbitrariness, thereby violating the fundamental principles of natural justice. [Para 33] Doctrines/Principles – Doctrine of legitimate expectation – Whether doctrine of legitimate expectation override an express provision of law or the Constitution:

Held: It is well-settled that the doctrine of legitimate expectation cannot override an express provision of law or the Constitution – It must be borne in mind that the expectation must be legitimate, in the sense that it is not only reasonable but also legally sustainable within the structure of the governing statute or constitutional scheme – In the event of any conflict between an expectation and the existing legal framework, the expectation has to run hand in hand with the legal intent and not against it – The doctrine of legitimate expectation is not a rigid rule and must be conceded where a superseding public interest or a statutory or constitutional bar exists – Thus, while legitimate expectation may guide how discretionary powers are exercised, it cannot be invoked to compel an authority to act contrary to a binding legal or constitutional command. [Para 34]