Which of the following must a petitioner do before seeking judicial relief in an Article 78 proceeding?

In an Article 78 proceeding, the petitioner is required to exhaust all available administrative remedies before seeking judicial relief. This means that the petitioner must first utilize any internal agency processes or administrative options available to resolve their grievance. The rationale behind this requirement is to encourage the use of administrative procedures designed to address disputes, allowing agencies to correct their own errors and promote efficiency in the system.

If a petitioner bypasses these administrative avenues and directly approaches the court, the court may dismiss the case on the grounds that the petitioner did not give the agency a chance to review and possibly resolve the issue. This helps to ensure that all potential solutions are considered before resorting to judicial intervention.

The other options listed do not align with the procedural prerequisites of an Article 78 proceeding, further supporting why the requirement to exhaust administrative remedies is crucial.