Which of the following is NOT a ground for filing an Article 78 petition?

• A. Certiorari
• B. Prohibition
• C. Mandamus to Compel
• D. Injunction

Answer: (D)

Article 78 petitions are the New York remedy for challenging administrative actions, and the recognized routes to obtain relief are certiorari to review the agency’s decision for errors, prohibition to stop actions beyond the agency’s jurisdiction, and mandamus to compel a nondiscretionary duty. An injunction, while a common tool in other civil actions, is not a ground for an Article 78 petition. It represents a form of relief more typical in general equity or separate civil proceedings, not a standalone basis for Article 78 review. Therefore, injunction doesn’t fit as one of the authorized grounds for an Article 78 petition; the petition would instead proceed under certiorari, prohibition, or mandamus to compel depending on the situation.