53. Nevertheless, it was Vineet Narain and others v. Union of
India and another (AIR 1998 SC 889), where the Supreme Court
coined medium of continuing mandamus. The Court monitored the investigation of the case to ensure that the authorities abide by its
directions. It held that “the medium of continuing mandamus was a
new tool forged because of the peculiar needs of the matter.”
Thereafter, the superior courts in India granted relief of continuing
mandamus in a number of cases. For this reference may be made to
M.C. Mehta v. Union of India [(2008) 1 SCC 407], Swaraj Abhiyan
(IV) v. Union of India (AIR 2016 SC 2953), Manushi Sangthan Delhi
v. Govt. of Delhi (Delhi) [2010(168) DLT 168], and Mahendra Lodha
v. State of Rajasthan [RLW 2007(2) Raj. 1428].
Lahore High Court
Writ Petition-Criminal Proceedings-Detention/habeas
409-20
2020 LHC 200

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