1
AFR
HIGH COURT OF CHHATTISGARH, BILASPUR
Judgment Reserved on: 15/05/2019
Judgment Delivered on : 17/05/2019
Writ Appeal No. 262 of 2019
{Arising out of order dated 20.03.2019 passed in Writ Petition (T) No. 60
of 2019 by the learned Single Judge}
M/s. Brandavan Food Products (A company incorporated under the
SectionCompanies Act, 1956) Plot No. 327, Ward 18, Near Post Office,
Deepak Nagar, Durg, Chhattisgarh, Through its authorised
signatory Mr. Rajeev Kumar Gupta, S/o Shri B.K Gupta, Aged bout
44 years, R/o Lavahandi, Raipur, Chhattisgarh.
—- Appellant
Versus
1. Commissioner (Appeals), Central State Goods and Service Tax
Raipur Commissionerate Central GST Building, Dhamtari Road,
Tikrapara, Raipur, Chhattisgarh.
2. Additional Commissioner, Central State Goods Service Tax,
Raipur, Commissionerate Central GST Building, Dhamtari Road,
Tikrapara, Raipur, Chhattisgarh.
—- Respondents
AND
Writ Appeal No. 263 of 2019
{Arising out of order dated 20.03.2019 passed in Writ Petition (T) No. 59
of 2019 by the learned Single Judge}
M/s. R.K. Associates and Hoteliers Pvt. Ltd. (A company
incorporated under the SectionCompanies Act, 1956) Room No. 1,
Panchvati, Deepak Nagar, Durg, Chhattisgarh, Through its
authorised signatory Mr. Rajeev Kumar Gupta, S/o Shri B.K Gupta,
Aged bout 44 years, R/o Lavahandi, Raipur, Chhattisgarh.
—- Appellant
Versus
2
1. Commissioner (Appeals), Central State Goods and Service Tax
Raipur Commissionerate Central GST Building, Dhamtari Road,
Tikrapara, Raipur, Chhattisgarh.
2. Additional Commissioner, Central State Goods Service Tax,
Raipur, Commissionerate Central GST Building, Dhamtari Road,
Tikrapara, Raipur, Chhattisgarh.
—- Respondents
AND
Writ Appeal No. 264 of 2019
{Arising out of order dated 20.03.2019 passed in Writ Petition (T) No. 58
of 2019 by the learned Single Judge}
M/s. Satyam Caterers Pvt. Ltd. (A company incorporated under the
SectionCompanies Act, 1956) Room No. 2, Panchvati, Deepak Nagar,
Durg, Chhattisgarh, Through its authorised signatory Mr. Rajeev
Kumar Gupta, S/o Shri B.K Gupta, Aged bout 44 years, R/o
Lavahandi, Raipur, Chhattisgarh.
—- Appellant
Versus
1. Commissioner (Appeals), Central State Goods and Service Tax
Raipur Commissionerate Central GST Building, Dhamtari Road,
Tikrapara, Raipur, Chhattisgarh.
2. Additional Commissioner, Central State Goods Service Tax,
Raipur, Commissionerate Central GST Building, Dhamtari Road,
Tikrapara, Raipur, Chhattisgarh.
—- Respondents
AND
Writ Appeal No. 265 of 2019
{Arising out of order dated 20.03.2019 passed in Writ Petition (T) No. 57
of 2019 by the learned Single Judge}
M/s. R.K. Associates and Hoteliers Pvt. Ltd. (A company
incorporated under the SectionCompanies Act, 1956) Room No. 1,
Panchvati, Deepak Nagar, Durg, Chhattisgarh, Through its
authorised signatory Mr. Rajeev Kumar Gupta, S/o Shri B.K Gupta,
Aged bout 44 years, R/o Lavahandi, Raipur, Chhattisgarh.
—- Appellant
3
Versus
1. Commissioner (Appeals), Central State Goods and Service Tax
Raipur Commissionerate Central GST Building, Dhamtari Road,
Tikrapara, Raipur, Chhattisgarh.
2. Additional Commissioner, Central State Goods Service Tax,
Raipur, Commissionerate Central GST Building, Dhamtari Road,
Tikrapara, Raipur, Chhattisgarh.
—- Respondents
For Appellant : Shri Chetan Sharma, Senior Advocate
alongwith Shri Gagan Gupta, Shri Abhinit Das
and Shri Romir S. Goyal, Advocates.
For Respondent/Revenue : Shri Maneesh Sharma, Advocate.
Hon’ble Shri P.R. Ramachandra Menon, Chief Justice
Hon’ble Shri Manindra Mohan Shrivastava, Judge
C.A.V. Judgment
Per P.R. Ramachandra Menon, Chief Justice
1. Whether the interference declined to entertain the merit of the case
by the statutory authorities and also by a learned Judge of this Court
dismissing the appeals/writ petitions for the reason that the appeal was filed
beyond the maximum time limit stipulated under the statute even after the
condonable extent of delay, is correct or not is the question mooted for
consideration in these appeals.
2. The thrust of the argument is that the power of this Court under
SectionArticle 226 of the Constitution is quite wider enough to extend the relief with
regard to the merit involved and that the technical ground of delay cannot be
a bar in this regard.
3. Four different appeals arise from four different proceedings, all of
which were dealt together by the learned Single Judge by passing a common
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judgment dismissing the writ petitions. Writ Appeal No. 265 of 2019 is treated
as the lead case, as suggested by the learned Senior Counsel for the
Appellants.
4. We have heard Shri Chetan Sharma, the learned Senior Counsel
appearing for the Appellants and Shri Maneesh Sharma, learned Standing
Counsel for the Respondents/Department/Revenue.
5. The crux of the factual matrix reveals that the Appellants are
supplying bed-rolls and newspapers as required by the award of the contract
by M/s. Indian Railways and IRCTC subject to the terms and conditions as
agreed upon. The duty cast upon the Appellants based on the contracts was
being discharged accordingly and while so, they were served with a show
cause notice proposing to tax the supply of newspapers under Section
65(105)(zzt) read with Section 67(76a) and Section 65(24) as ‘outdoor
catering service’, while supply of bed-rolls was proposed to be taxed under
the category of ‘business support service’ under Section 65(105c) read with
Section 65(10)(zzzq) of the Finance Act, 1994 (for short ‘the Act, 1994’).
6. According to the Appellants, the notice was absolutely without any
basis as the delivery of goods sold at the direction of the buyer would not
involve any services and it does not fall within the definition of ‘caterer’ under
Section 65(24) and the ‘outdoor caterer’ under Section 65(76a) of the Act so
as to constitute any ‘outdoor catering service’. It is similarly contended that
supply of bed-rolls and its maintenance also would not qualify to be branded
as ‘business support service’. The explanation submitted by the Appellant in
this regard was considered but it was turned down and the assessment
proceedings were finalised by the competent authority. Met with the situation,
a statutory appeal was preferred before the Commissioner (Appeals) which is
belated by 253 days and hence, it was sought to be condoned by filing a
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petition to condone the delay. The matter was examined by the
Commissioner (Appeals) who found that as per the relevant provisions of the
statute, the appeal had to be filed within ‘two months’ and thereafter, the
delay, if any could be condoned to a maximum period of ‘one month’, on
offering sufficient cause. By virtue of the undisputed facts, the appeal was
filed belatedly even beyond the condonable extent. The appellate authority
dismissed the application for condonation of delay holding that there was no
power to condone the said extent of delay and as a natural consequence, the
appeal as well.
7. The Appellants moved the Customs, Excise Service Tax
Appellate Tribunal, New Delhi (for short ‘the Tribunal’) challenging the course
and proceedings finalised by the appellate authority i.e. the Commissioner
(Appeals) also pointing out that the merit was squarely covered in favour of
the Appellant and that the delay had to be condoned in view of the reasons
specifically stated for the delay. However, the appellate authority also took
the very same stand as taken by the Commissioner (Appeals) and the
appeals came to be dismissed in view of the inordinate delay beyond the
extent as specified in the statute, thus, without entertaining the merits. This
made the Appellants to approach this Court by filing writ petitions referring to
the sequence of events and trying to explain the delay, particularly in
connection with the demise of the mother of the authorised signatory and
also with reference to the unforeseen situations resulted in connection with
the marriage of the daughter of the deponent and also the registration of a
crime in connection with the affairs.
8. The learned Single Judge considered all the connected matters
together and as per the common judgment dated 20.03.2019 held that the
issue involved was no longer res integra as concluded/declared by the Apex
Court in SectionSingh Enterprises v. Commissioner of Central Excise,
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Jamshedpur {(2008) (221) ELT 163 (SC) : (2008) 3 SCC 70}. Reference
was also made to the decision sought to be cited by the Appellants in SectionM/s.
Shri Sai Rolling Mill v. The Commissioner, Customs, Central Excise
Service Tax Others; WA No. 322 of 2017 decided on 15.11.2018 whereby
the appeal against dismissal of the writ petition was disposed off remitting the
matter back to the Central Excise authority for consideration. The learned
Single Judge observed that the facts and situation in M/s. Shri Sai Rolling
Mill (supra) was totally different and with reference to the factual position
involved, it was held that no extraordinary circumstance was substantiated by
the Appellant/Petitioner to warrant interference by invoking the powers of this
Court under SectionArticle 226 of the Constitution of India, in turn leading to
dismissal of the writ petitions. This is to the chagrin of the Appellants who
have filed these appeals seeking indulgence of this Court.
9. Shri Chetan Sharma, the learned Senior Counsel appearing for the
Appellants submits that the appeals have been preferred under some firm
grounds as noted below:
• That, the power of this Court under SectionArticle 226 of the
Constitution is wide enough to render justice and that the legal
position as to the exigibility to tax in respect of the two
instances of sale sale/supply having already been answered in
favour of the Assessees with reference to other instances, the
delay in the instance case was never to be reckoned a hurdle
under any circumstances.
• Section 34 of the Arbitration and SectionConciliation Act, 1996
stipulates that the appeal has to be filed within three months
and that no appeal shall be entertained thereafter. Such
terminology, giving a mandate ‘not to entertain the appeal’ is
7conspicuously absent in the instant case, where the appeal is
preferred under Section 85(3A) of the Act, 1994 and hence, the
delay ought to have been condoned by the statutory authorities
as well as by the learned Single Judge.
• The legal position in this regard has been explained by the Full
Bench of the Gujarat High Court in SectionPanoli Intermediate
(India) v. Union of India Others; {(2015) 326 ELT532 :
(2015) 3 KLT 30} and that the relevant statutory provision dealt
with thereof is virtually identical to Section 85(3A) of the Act,
1994. The said decision stands in favour of the Appellant, and
hence, the verdict passed by the learned Single Judge is liable
to be interdicted.
• Reliance is also sought to be placed on several other verdicts;
viz; SectionCommissioner of Income Tax v. Chhabil Dass Agrawal;
(2014) 1 SCC 603; Raja Mechanical Company (P) Ltd. v.
Commissioner of Central Excise, Delhi-I; (2012) 279 ELT
481; SectionState of Nagaland v. Lipok AO and Others; (2005) 3
SCC 752; SectionCommissioner of Income Tax v. Kasturi Sons;
(1999) 3 SCC 346; Uma Textiles Processors v. Union of
India; (2013) 290 ELT 214; The Food Inspector, Cannanore
Municipality, Cannanore v. M. Gopalan; (1991) AIR (Kerala)
240; M.P. Steel Corporation v. Commissioner of Central
Excise; {(2015) 319 ELT 373 : (2015) 7 SCC 58}; Central
Industrial Security Force v. Commissioner of CGST C.
Ex.; (2018) 14 GSTL 198; Sai Rolling Mill, A partnership
firm registered v. Commissioner, Custom, Central Excise
Service Tax; Writ Appeal No. 322 of 2017, decided on
15.11.2018; SectionITC Ltd. Another v. Union of India (UOI)
Others; SLP(C) No 11508 of 1998, decided on 22.08.1990 and
8SectionStar Battery Ltd. v. Assistant Commissioner, C. Ex; (2011)
264 ELT 363.
• During the course of submission, learned Senior Counsel
submits with specific reference to Uma Textiles (supra), MP
Steel Corporation (supra) and a Division Bench judgment of
this Court in Sai Rolling Mill (supra), besides making
reference to a Division Bench verdict passed by the Allahabad
High Court in Central Industrial Security Force (supra) and
that of a Single Bench of the Calcutta High Court in Star
Battery Ltd. (supra) that the orders/verdict under challenge
have caused miscarriage of justice.
• Despite the specific pleading as to the extraordinary
circumstances under ‘two’ different heads (mother’s case and
the daughter’s marriage, respectively); the learned Single
Judge dealt with only one head (the marriage of the daughter)
and held that it was not an extraordinary circumstance for
condoning the delay. The reason stated is that the Petitioner/
Appellant was still running the business throughout,
notwithstanding the tragedy. It is stated that the omission to
consider the other ground (with reference to the mother’s
death) has caused substantial prejudice to the Appellants and
hence, interference is required, adding that the Appellant was
only acting as a dutiful son, in discharge of his duties towards
his mother in terms of the principle “matru devo bhava”.
• A Division Bench of the Gujarat High Court in Uma Textiles
(supra) (para 1 and 5) has condoned the delay beyond the
statutory limit, in exercise of the power under SectionArticle 226 of the
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Constitution of India, holding that the endeavor of the Court
always shall be to promote justice leaning towards the merits
and not to non-suit the parties on technicalities.
10. Shri Maneesh Sharma, the learned Standing Counsel for the
Respondent/Revenue points out that the Appellants had failed to make out
any point to be considered as involving ‘extraordinary case’ for invoking the
power of this Court under SectionArticle 226 of the Constitution of India. The matter
was considered in the said context by the learned Single Judge who
categorically held that the reason/explanation offered could never be taken to
infer that it was an ‘extraordinary case’. That apart, a Division Bench of this
Court has already held as per judgment dated 29.11.2018 in TAXC No. 19 of
2017 that when the particular statute stipulates the time for filing appeal
mentioning the parameters, the provisions of other statutes cannot be looked
into, nor is it possible to make any comparative analysis. Reliance is sought
to be placed on paragraphs 5, 6, 7, 8 and 9 of the said judgment.
11. The above discussion leads to the core question as to the scope of
Section 85(3A) of the Act, 1994, the extent and power to condone the delay
under the said provision and the scope of interference by this Court in
exercise of the discretionary/extraordinary jurisdiction under SectionArticle 226 of the
Constitution of India. For convenience of reference, Section 85(3A) of the Act,
1994 is extracted below:
“85. (3A). An appeal shall be presented within two
months from the date of receipt of the decision or
order of such adjudicating authority, made on and
after the Finance Bill, 2012 receives the assent of
the President, relating to service tax, interest or
penalty under this Chapter:
Provided that the Commissioner of Central Excise
(Appeals) may, if he is satisfied that the appellant
was prevented by sufficient cause from presenting
the appeal within the aforesaid period of two
10months, allow it to be presented within a further
period of one month. ”
12. There is no dispute to the fact that the appeal came to be filed
before the appellate authority only after 253 days beyond the stipulated
period of ‘two months’ and hence, it was sought to be condoned by filing an
application. The maximum condonable limit as per the statute is only ‘one
month’, after the prescribed period of two months. This being the position,
whether it could have been condoned by the statutory authority and if not
possible, could it have been dealt with granting relief by this Court in exercise
of the jurisdiction under SectionArticle 226 of the Constitution, is the only question.
13. We have gone through all the verdicts cited from the part of the
Appellants and it is true that a Division Bench of the Gujarat High Court had
condoned the delay beyond the statutory extent in exercise of power under
SectionArticle 226 of the Constitution as held in Uma Textiles (supra). The questions
considered by the Full Bench of the Gujarat High Court in Panoli
Intermediate (India) (supra) are as extracted below:
“(1) Whether the period of limitation provided of 60
days, for filing an appeal under Section 35 of the
Central Excise Act, 1944, could be extended only
upto to 30 days as provided by the proviso or the
delay beyond the period of 90 days could also be
condoned in filing an appeal.
(2) Whether a statutory remedy or appeal is provided
under Section 35 of the Central Excise Act, 1944 and
the delay cannot be condoned under Section 35
beyond the period of 90 days, then whether Writ
Petition under SectionArticle 226 of the Constitution of India
would lie for the purpose of condoning the delay in
filing the appeal?
(3) When if the statutory remedy or appeal under
Section 35 is barred by the law of limitation whether
in a Writ Petition under SectionArticle 226 of the Constitution
of India, the order passed by the original adjudicating
authority could be challenged on merits?
Referring to Singh Enterprises (supra), it was held that the Apex
Court was considering the scope and ambit of sufficient cause found in the
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various statutes and thereby to consider to give effect to the statutory
provision made for limitation. It was further observed that the question as to
whether the provisions of Section 35 of the Central Excise Act, 1944 affects
the jurisdiction of the High Court under SectionArticle 226 of the Constitution of India
for exercise of the constitutional power or not was not considered by the Apex
Court. In paragraph 28, the Bench observed as follows:
“28. In the decision of the Apex Court in the case of Singh
Enterprises Vs. Commissioner of Central Excise
Jamshedpur and Others, (2008) 1 CLT 709 : (2008) 124
ECC 1 : (2008) 150 ECR 1 : (2008) 221 ELT 163 : (2007)
14 SCALE 610 : (2008) 3 SCC 70 : (2008) 12 VST 542 :
(2008) AIR SCW 1461 : (2007) 8 Supreme 533, which
has, been relied upon by the learned counsel Mrs. Parikh,
the Apex Court was considering the scope and ambit of
sufficient cause found in the various statutes and thereby
to consider to give the effect of statutory provision made
for limitation. In the said case, the question as to whether
the provisions of Section 35 of the Act affects the
jurisdiction of the High Court under SectionArticle 226 of the
Constitution for exercise of the constitutional power or not
was not considered by the Apex Court. Therefore, the
contention of the learned counsel Mr. Parikh that the
decision of the High Court taking the view that it had no
power to condone the delay after the expiry of the period
of 30 days should mean that the High Court will have no
jurisdiction under SectionArticle 226 in a case where the period of
30 days is over cannot be countenanced for the simple
reason that whether the High Court should exercise the
power to condone the delay after expiry of the period of
30 days while exercising the power under SectionArticle 226 of
the Constitution is one thing, but whether the jurisdiction
of the High Court under SectionArticle 226 of the Constitution is
affected by the statutory provision of Sectionsection 35 of the Act
is another thing. It cannot be disputed if the High Court
declines to exercise the power after the expiry of the
period of 30 days if the case is not falling in the
exceptional circumstance where gross injustice is not
satisfactorily demonstrated before the High Court. Hence,
the said decision is of no help to Mr. Parikh for canvassing
his contention.”
14. In Central Industrial Security Force (supra), a Division Bench of
the Allahabad High Court, as discernible from the discussions in paragraphs
2, 6, 8 and 10, held that by virtue of the statutory mandate, it could not be
stated that there was any illegality in not condoning the delay; but considering
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the ends of justice, the High Court chose to condone the delay, in exercise of
jurisdiction under SectionArticle 226 of the Constitution of India.
15. It is true that some of the High Courts, including this Court, at
times, have considered the question with reference to the ‘extraordinary
circumstances’, to condone the delay beyond the statutory limit as mentioned
above. The learned Single Judge specifically noted that the reason for the
delay of 253 days in filing the appeal offered by the writ petitioner was that
after passing of the assessment order, the Appellant/Petitioner was engaged
in personal tragedy as his daughter was facing marital dispute and hence, the
appeal could not be filed within the time. In paragraph 9, the learned Single
Judge also observed that the so-called extraordinary situation pressed by the
Petitioner was not of such nature which had paralyzed the Petitioner’s
business or his life and that admittedly, he was carrying on his business
during the relevant period. Hence, according to the learned Judge, there was
no pressing emergency which did not permit the Petitioner to prefer an
appeal before the Commissioner (Appeals) on time. The reasoning given by
the learned Single Judge is not liable to be interdicted as unsustainable
under any circumstances.
16. The learned Senior Counsel for the Appellants submits that the
learned Single Judge considered only ‘one’ of the two grounds raised and
with reference to the extraordinary circumstance that there was another
ground in relation to the demise of the mother of the Petitioner as specifically
pleaded in the writ petition. This, however, was omitted to be considered and
hence requires interference.
17. We asked a specific question whether such a ground
pleaded/stated was ever argued before the learned Single Judge, to which
the learned Senior Counsel fairly submitted that he was not aware, as a
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different counsel was dealing with the situation at that point of time. Be that
as it may, the learned Senior Counsel submits that the Appellant/Petitioner
was only discharging his duty as a dutiful son honouring the values of
motherhood, following the doctrine “matru devo bhava”. This Court is aware
of the unparalleled status of a mother in the society and the vacuum resulted
in the lives of her children. This Court is also aware of the teachings in the
Upanishads, particularly the Taittiriya Upanishad, which says: “maatru
devo bhava, pitru devo bhava, aachaarya devo bhava; atithi devo
bhava”, (be a man to whom mother is god, be a man to whom father is god,
be a man to whom teacher is god, and be a man to whom guest is a god).
When the Appellant contends that he was otherwise engaged in connection
with the demise of his mother, even if it is acceptable, it cannot cover the
inordinate delay of 253 days during which period, the Appellant did not find it
necessary to compromise with the business activities and other commercial
transactions. It has to be reasonably presumed that this plea under this head
was never argued before the learned Single Judge; which otherwise would
have found a place in the judgment, dealing with the same in appropriate
manner. If the Appellant has got a case that it was argued, but omitted to be
considered, the redressal of the grievance could only be by way of filing a
review petition and nothing else. But since we are holding that the inordinate
delay of 253 days cannot be covered by the said incidence/incident, during
which period the Appellant was admittedly carrying on the commercial
activities/business, it does not constitute any ‘extraordinary circumstance’ to
have interfered by this Court, invoking the discretionary power under SectionArticle
226 of the Constitution of India.
18. During the course of hearing, this Court put across the latest
judgment rendered by the Apex Court on the point, as decided in Oil and
Natural Gas Corporation Ltd. v. Gujarat Energy Transmission
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Corporation Limited Others; (2017) 5 SCC 42. It was with regard to the
belated appeal filed in terms of Section 125 of the Electricity Act, 2003
against the order passed by the Appellate Tribunal. The said provision reads
as follows:
“125. Appeal to Supreme Court. – Any person
aggrieved by any decision or order of the Appellate
Tribunal, may, file an appeal to the Supreme Court
within sixty days from the date of communication of
the decision or order of the Appellate Tribunal, to him,
on any one or more of the grounds specified in
section 100 of the Code of Civil Procedure, 1908
(5 of 1908):
Provided that the Supreme Court may, if it is
satisfied that the appellant was prevented by
sufficient cause from filing the appeal within the said
period, allow it to be filed within a further period not
exceeding sixty days.”
19. The above provision stipulates that the statutory remedy against
the verdict of the Appellate Tribunal was to be by way of an appeal to be
preferred before the Supreme Court within 60 days from the date of
communication of the order; with a proviso to have the delay, if at all any , to
be condoned within a further period not exceeding 60 days. The scope of the
said provision was considered with reference to the various rulings rendered
by the Apex Court on the point, particularly, in Chhattisgarh SEB v. Central
Electricity Regulatory Commission; (2010) 5 SCC 23, the verdict passed
by the Apex Court in Singh Enterprises (supra) sought to be relied on by
both the Appellants and also by the Respondent (extracted and relied on by
the learned Single Judge as well), SectionSuryachakra Power Corporation v.
Electricity Department; (2016) 16 SCC 152; M.P. Steel Corporation
(supra) and such other verdicts.
20. After a threadbare analysis of the provisions of law and the
precedents, it was declared in categorical terms by the ‘three member Bench’
that, once the period of limitation is specifically prescribed in a statute and
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stipulates the maximum period/extent of delay which can be condoned, it
cannot be condoned by the Apex Court even in exercise of the power under
SectionArticle 142 of the Constitution of India. Having said so, the Appellants cannot
be heard to say that the High Court is still having power to condone the delay
beyond the prescribed extent under the statute, by invoking the power under
SectionArticle 226 of the Constitution, which in fact will be amounting to re-writing the
law and contrary to the verdict passed by the Apex Court, which is having a
binding effect all over India in view of SectionArticle 141 of the Constitution of India.
There is no answer from the part of the Appellants to the law declared by the
‘three member Bench’ of the Apex Court in Oil and Natural Gas
Corporation Ltd. (supra) but for stating that the said judgment is not
applicable, despite the fact that it has been rendered with reference to the
judgments sought to be relied on by the Appellant, as discussed above.
21. In the above facts and circumstances, we are of the firm view that
the verdict passed by the learned Single Judge is perfectly within the four
walls of law and is not assailable under any circumstances. Interference is
declined and all the appeals stand dismissed accordingly. The parties shall
bear their costs.
Sd/- Sd/-
(P. R.Ramachandra Menon) (Manindra Mohan Shrivastava)
CHIEF JUSTICE JUDGE
Amit