PURAN SINGH & ORS. vs STATE OF PUNJAB & ORS.

The Supreme Court upheld the High Court's dismissal of a writ petition filed by Sham Singh's heirs, affirming that the petition abated due to the failure to substitute the deceased respondent, Bir Singh, as required under Order 22 of the Code of Civil Procedure. The Court clarified that the principles of substitution apply to writ proceedings under Article 226 of the Constitution of India. Consequently, the appeal was dismissed, reinforcing the necessity of legal representation in such cases.