Naming Of Public Departments Purely Within Govt Domain: Madras High Court Dismisses Plea For Renaming Tamil Development Department

The bench of Chief Justice Manindra Mohan Shrivastava and Justice G Arul Murugan observed that the naming and renaming of a public department was within the domain of the government, and the court could not exercise jurisdiction under Article 226 of the Constitution to do the same.

“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,” the court said.

The petitioner, Muthu Subramaniam had approached the court after his request for the same was rejected by the Director of Tamil Nadu development. Subramaniam had argued that the word “development” could not be equated with the word “Valarchi”. He submitted that the word “valarchi” meant growth, increase, enrichment, etc whereas development had a different connotation meaning like upliftment, betterment etc. The petitioner thus sought to change the name of the department.

The court noted that there was no urgency in the matter as the impugned order was passed by the department in 2022 and the same was challenged only in 2025, after a lapse of 3 years. Thus, the court opined that there was no reason to invoke the extraordinary jurisdiction of the high court under Article 226 of the Constitution.

The court also observed that the issue involved in the present plea was not a public issue and non consideration of the same would not affect the public at large.

“Moreover, the issue involved is not of such gravitas that the non-consideration of the same would impair the society at large. 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,” the court said.

The court also noted that there was no malafide in the order passed by the department. Thus, noting that it was not a case warranting interference, the court dismissed the plea.

Counsel for Petitioner: Mr. N. Umapathi

Counsel for Respondents: Mr. M. Suresh Kumar Additional Advocate General assisted by Mr. M. Habeeb Rahman Government Advocate

Case Title: Muthu Subramaniam v. The State Government of Tamil Nadu

Citation: 2025 LiveLaw (Mad) 441

Case No: W.P.No.43202 of 2025

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