Shah v. City of New York

2025 NY Slip Op 30029(U)
CourtNew York Supreme Court, New York County
DecidedJanuary 6, 2025
DocketIndex No. 161092/2024
StatusUnpublished

This text of 2025 NY Slip Op 30029(U) (Shah v. City of New York) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Shah v. City of New York, 2025 NY Slip Op 30029(U) (N.Y. Super. Ct. 2025).

Opinion

Shah v City of New York 2025 NY Slip Op 30029(U) January 6, 2025 Supreme Court, New York County Docket Number: Index No. 161092/2024 Judge: Judy H. Kim Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. FILED: NEW YORK COUNTY CLERK 01/06/2025 05:07 PM INDEX NO. 161092/2024 NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 01/06/2025

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. JUDY H. KIM PART 04 Justice ---------------------------------------------------------------------------------X INDEX NO. 161092/2024 WAJID SHAH, MOTION DATE 11/29/2024 Petitioner, MOTION SEQ. NO. 003 -v- THE CITY OF NEW YORK, DECISION + ORDER ON MOTION Respondent. ---------------------------------------------------------------------------------X

The following e-filed documents, listed by NYSCEF document number (Motion 003) 9, 10, 11, 12, 13, 14, 15, 16 were read on this motion for ARTICLE 78 (BODY OR OFFICER) .

Petitioner is a mobile food vendor in New York City. At some point unspecified prior to

the events at issue here, he was issued a mobile food vending unit permit, under permit number

50130362 by respondent New York City Department of Health and Mental Hygiene. On June 28,

2023, however, petitioner was granted a different permit, under permit number 50131225 (the

“Second Permit”) and the First Permit was withdrawn pursuant to Administrative Code §17-

307(2)(C), which precludes a vendor from holding more than one such permit at a time. This

Second Permit was subsequently revoked.

On or about December 21, 2023, petitioner commenced a special proceeding under index

number 162319/2023 to compel respondent to reinstate the Second Permit and, upon its

reinstatement, transfer this permit to his wife (the “First Proceeding”). In a decision and order

dated June 18, 2024, the Petition was granted to the extent that respondent was directed to reinstate

the Second Permit or its functional equivalent (Index No. 162319/2023, NYSCEF Doc. No. 57).

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The Court added that since respondent had never granted or denied petitioner’s request to transfer

the Second Permit (instead revoking it), this issue was not ripe for judicial review (Id.).

On November 20, 2024, petitioner filed orders to show cause in the First Proceeding

seeking to compel respondent to issue a formal determination regarding his request to transfer his

MFV Supervisory License (which grants a holder the ability to vend in New York City and is

distinct from the permits referenced above, which relate to specific mobile food vending units) to

his wife and issue a determination on his June 30, 2024 request for reissuance of the First Permit.

The Court declined to sign these orders to show cause, as the relief sought was beyond the scope

of that special proceeding. In doing so, however the Court directed the parties to appear for a

conference on December 11, 2024, to “discuss respondent’s compliance with the directives of the

June 18, 2024, order.”

On November 29, 2024, petitioner commenced the instant special proceeding, by petition

and order to show cause compelling respondent to issue a determination on his June 30, 2024

request for reissuance of the First Permit and asserting that the withdrawal of the First Permit was

arbitrary and capricious and contrary to Administrative Code §17-307(2)(C) and General Business

Law §§32 and 35. Petitioner then filed two additional orders to show cause, seeking orders

compelling respondent to issue a formal determination regarding Petitioner’s June 18, 2024

application to transfer his Mobile Food Vending Supervisory License to his spouse and schedule

a pre-permit inspection of his mobile food cart, a necessary predicate to the reinstatement of the

Second Permit.

The Court signed the third order to show cause, concerning the pre-permit inspection, and

scheduled argument for December 11, 2024, the same date as the conference scheduled in the prior

special proceeding. At the parties’ appearance on that date, respondent agreed to schedule an

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inspection of petitioner’s mobile food vending unit within five days and reissue the Second Permit

upon a satisfactory inspection. The Court also issued an order to that effect (Index No.

162319/2023, NYSCEF Doc. No. 156). At that appearance, petitioner represented to the Court that

the reinstatement of the Second Permit would moot the relief sought regarding his request for the

reinstatement of the First Permit, the sole issue raised in the petition in this special proceeding.

On January 1, 2025, filed a fourth order to show cause in the present special proceeding

seeking an order declaring that the purported transfer of his Disabled Veteran Supervisory License

to his spouse was invalid and directing that his Disabled Veteran Supervisory License

(#41618198) be restored within five (5) business days (NYSCEF Doc. No. 30 [Proposed Order to

Show Cause]). In his affirmation in support of this order to show cause, he averred that the Second

Permit had been reinstated and, at his request, transferred to his wife but asserted that his Disabled

Veteran Supervisory License (#41618198) had also been “transferred” to her without his consent.

Ultimately, as petitioner acknowledged at oral argument, the petitioner and first order to

show cause in this special proceeding are mooted by respondent’s reissuance of the Second Permit

to petitioner. As to his second order to show cause, seeking an order compelling respondent to

transfer the Second Permit to his wife, this relief is beyond the scope of the petition but is, in any

event, mooted by petitioner’s representation that the permit was in fact transferred. The third order

to show cause, seeking a pre-permit inspection of the mobile food vending cart, is also outside the

scope of the petition but similarly moot, as there is no dispute that the pre-permit inspection was

held as ordered.

Finally, the Court declines to sign petitioner’s fourth order to show cause. This order to

show cause includes factual allegations and seeks relief beyond that included in the petition.

Petitioner is advised that an order to show cause is only a mechanism through which petitioner

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notifies respondent of the commencement of a special proceeding (See Clinton-178 Towers LLC

v Chapple, 58 Misc 3d 198, 204 [Civ Ct, Bronx County 2017]) and is not an avenue by which

petitioner can add new factual allegations and seek new relief after the petition is filed. As the

issues raised in the petition in this special proceeding have been resolved, petitioner’s challenge to

respondent’s conduct after the pre-permit inspection and reissuance of the Second Permit—

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§ 32
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Bluebook (online)
2025 NY Slip Op 30029(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/shah-v-city-of-new-york-nysupctnewyork-2025.