JUDGMENT : Pushpendra Singh Bhati, J. 1. The present writ petition (PIL) has been preferred under Article 226 of the Constitution of India, claiming the following reliefs: “It is therefore, humbly prayed on behalf of petitioner that this writ petition for Public Interest Litigation may kindly be allowed and by an appropriate, writ, order or direction may kindly be issued to respondent and the following directions may kindly be passed for purpose to saving the life of the Cows and calf living with the Goshalas of the State of Rajasthan.- a) That by an appropriate writ direction the State of Rajasthan may kindly be directed to provide the assistance/ grant to all recognized Goshala if they fulfill the conditions of the guidelines dated 03.03.2023 while exclude the clause 19 of the guideline dated 03.03.2023 b) That by an appropriate writ, direction and order, the clause XIX of the guideline dated 03.03.2023 (annex-12) issued by department of Gopalan may kindly be declared illegal, against the Rules and same may be set aside. c) That by an appropriate writ, direction and order the Gopalan Department may kindly be directed to not debar to any Goshala for obtaining the grant/assistance under the Rules of 2016 on the account of pending disputes with regard to title of the land or executive committee. d) That any other relief, which this Hon’ble Court deems fit, by which the petitioners may get full justice may also be allowed.” 2. The principal issue arising for consideration in the present writ petition concerns the denial of financial assistance and grants under the Gosanrakshan and Samvardhan Nidhi Rules, 2016 (hereinafter referred to as the ‘Rules of 2016’) to Goshalas that are otherwise eligible, inasmuch as they possess valid registration certificates, are duly recognized by the Gopalan Department, and fulfill all requisite conditions prescribed under the Rules, except for compliance with Clause XIX. 2.1. The Rules of 2016 envisage the creation of a dedicated fund for the conservation, protection and development of Goshalas, ensuring support for cattle welfare. However, Clause XIX stipulates that no grant shall be released to any registered Goshala if any dispute relating to land or the executive committee is pending before a competent court. The controversy therefore centers around the petitioner’s grievance that this exclusionary bar under Clause XIX operates harshly and arbitrarily, resulting in denial of essential financial assistance despite fulfillment of all substantive eligibility criteria. The controversy therefore centers around the petitioner’s grievance that this exclusionary bar under Clause XIX operates harshly and arbitrarily, resulting in denial of essential financial assistance despite fulfillment of all substantive eligibility criteria. 3. Learned counsel appearing on behalf of the petitioner submitted that the present PIL has been filed to safeguard the welfare and survival of cows and calves in Goshalas across the State of Rajasthan, many of which are facing severe hardship due to denial of financial assistance under the Rules of 2016 despite the Rules being intended to ensure adequate fodder, medical facilities, and maintenance for cattle. 3.1. Learned counsel further submitted that several Goshalas, though duly registered, recognised by the Gopalan Department, and complying with all eligibility conditions under the Rules of 2016, have been denied grant-in-aid solely due to Clause XIX of the Guidelines dated 03.03.2023, which prohibits release of grants to any Goshala with a pending dispute relating to land or its executive committee before a competent court. 3.2. Learned counsel also submitted that the restriction imposed by Clause XIX is unreasonable and arbitrary, as internal civil or administrative disputes cannot justify withholding assistance essential for the survival and welfare of cattle. 3.3. Learned counsel further submitted that Clause XIX has no foundation and therefore operates contrary to the object and scheme of the Rules, amounting to manifest arbitrariness and violating Articles 14 and 21 of the Constitution. 3.4. Learned counsel also submitted that the refusal to release grants due to Clause XIX defeats the very purpose of the welfare scheme by resulting in deprivation of fodder, water, shelter and medical care, causing avoidable suffering and death of cattle. 3.5. Learned counsel therefore submitted that Clause XIX of the Guidelines dated 03.03.2023 deserves to be set aside, and the State should be directed to release financial assistance to all eligible Goshalas without enforcing the said clause, in the interest of justice and humane treatment of animals. 4. Learned counsel appearing for the respondents submitted that the writ petition is misconceived and proceeds on an incorrect interpretation of the Rules of 2016 and the Guidelines dated 03.03.2023, which were framed to ensure transparent, accountable, and regulated disbursement of public funds earmarked for cattle welfare. 4.1. 4. Learned counsel appearing for the respondents submitted that the writ petition is misconceived and proceeds on an incorrect interpretation of the Rules of 2016 and the Guidelines dated 03.03.2023, which were framed to ensure transparent, accountable, and regulated disbursement of public funds earmarked for cattle welfare. 4.1. Learned counsel submitted that Clause XIX was incorporated to prevent misuse or diversion of grants in cases where disputes relating to title of land or control of the executive committee are pending before competent courts, creating uncertainty regarding legitimate management. It is submitted that releasing funds in such situations risks misappropriation and conflict-driven financial misuse, which the State is obligated to prevent. 4.2. Learned counsel submitted that mere registration or recognition of a Goshala does not confer an unconditional right to grant-in-aid, and eligibility is subject to compliance with all regulatory safeguards necessary for responsible utilisation of public funds. 4.3. Learned counsel submitted that the restriction under Clause XIX is regulatory and temporary, not punitive, and any Goshala may secure grant assistance upon resolution of its disputes or clarification of lawful administrative control. Hence, the clause cannot be termed arbitrary. 4.4. Learned counsel further submitted that Clause XIX was subsequently modified on 22.03.2023, shifting the sanctioning authority from the District Level Gopalan Committee to the District Level Gopalan Committee chaired by the District Collector, thereby securing greater neutrality, transparency, and administrative oversight. Learned counsel submitted that this modification reflects the State’s proactive approach in strengthening procedural safeguards based on practical challenges and ensures protection of public funds, reinforcing that the clause and the overall policy framework are both rational and enacted in public interest. 4.5. Learned counsel therefore submitted that Clause XIX and its modification constitute a reasonable and considered policy decision, and striking it down or directing unconditional grant release would undermine financial discipline and risk public money being released to disputed or unverified management bodies. 5. Heard learned counsel for the parties as well as perused the record of the case. 6. The controversy in the present public interest litigation is limited to the validity and operation of Clause XIX of the Guidelines dated 03.03.2023, issued under the Rules of 2016, which restricts grant-in-aid to Goshalas where disputes regarding land title or executive committee control are pending before a competent court. 6. The controversy in the present public interest litigation is limited to the validity and operation of Clause XIX of the Guidelines dated 03.03.2023, issued under the Rules of 2016, which restricts grant-in-aid to Goshalas where disputes regarding land title or executive committee control are pending before a competent court. The petitioner seeks a declaration that Clause XIX is illegal and unconstitutional and further prays for directions to the State to release financial assistance to all eligible Goshalas irrespective of such disputes. 6.1. For ready reference, Clause XIX of the Guidelines dated 03.03.2023 is reproduced as under: 7. This Court finds that the Rules of 2016 were framed with the clear objective of ensuring regulated, transparent, and accountable utilisation of public funds intended for cattle welfare. The Rules do not contemplate unconditional or automatic release of public money merely on the basis of registration or recognition. Public funds must be placed only in hands that are legally authorized, administratively stable, and responsible for their appropriate use, particularly where the purpose relates to animal welfare of significant societal importance. 8. This Court is unable to accept the petitioner’s contention that Clause XIX imposes an arbitrary barrier. Pendency of disputes related to land title or control of the executive committee creates genuine uncertainty as to who is lawfully entitled to manage the Goshala and to apply for grant of funds. In such circumstances, the State’s decision to temporarily withhold public funds until clarity emerges constitutes a reasonable and precautionary safeguard, designed to prevent diversion, misuse, or conflicting claims over expenditure. The clause is regulatory and temporary in nature and does not extinguish the right of any Goshala to seek assistance once the dispute reaches resolution. Accordingly, no element of manifest arbitrariness or discrimination is established. 8.1. This Court further observes that the distinction created by Clause XIX between Goshalas with undisputed management and those with pending disputes is founded on an intelligible differentia and bears a rational nexus to the objective of ensuring proper utilisation of public funds. The temporary embargo does not violate Articles 14 or 21, as it operates only until lawful control is clarified by a competent forum and does not, in itself, impede the welfare or humane treatment of cattle. 9. The temporary embargo does not violate Articles 14 or 21, as it operates only until lawful control is clarified by a competent forum and does not, in itself, impede the welfare or humane treatment of cattle. 9. This Court places significance on the modification dated 22.03.2023, whereby the authority for sanctioning grants was vested in the District Level Gopalan Committee chaired by the District Collector. The District Collector, being the senior-most administrative and revenue authority at the district level, is institutionally equipped to verify legal status, assess financial responsibility, and ensure neutrality in decision-making. His/her oversight provides a credible and independent evaluation of competing claims, particularly where disputes exist regarding management or ownership of a Goshala. By placing grant approval under an authority that is accountable, experienced in regulatory supervision, and removed from internal organizational conflicts, the modified structure ensures disciplined scrutiny of eligibility and safeguards public funds from being misdirected. This shift therefore strengthens transparency and ensures that welfare grants reach appropriate and duly authorized institutions, reflecting a deliberate and considered policy decision. 10. This Court is mindful of the settled principle that formulation of administrative policy, framing of guidelines, and decisions relating to allocation and prioritization of public funds primarily lie within the domain of the executive. In matters of policy evaluation, the scope of judicial intervention is limited to examining whether the decision-making process suffers from illegality, irrationality, procedural impropriety, or violation of constitutional or statutory provisions. In the present case, the material on record indicates that the policy mechanism has been developed through considered administrative reasoning and periodic refinement, and no ground has been made out to warrant intervention in exercise of writ jurisdiction. 11. For the reasons recorded hereinabove, this Court finds no legal infirmity, perversity, or arbitrariness in Clause XIX of the Guidelines dated 03.03.2023 or its modification dated 22.03.2023. The petitioner has failed to demonstrate any justification for exercise of extraordinary writ jurisdiction under Article 226. On the contrary, public interest strongly favours preservation of financial discipline and transparent administration rather than automatic release of funds during unresolved disputes. 12. Accordingly, the writ petition fails and is hereby dismissed. All pending applications stand disposed of.