Ms Maharaja Spices vs. Haryana Govt Excise And Taxation Department

Facts

The petitioner, M/s Maharaja Spices, filed a writ petition before the Punjab and Haryana High Court challenging an order dated 16.06.2025 passed under Section 130 of the Haryana Goods and Services Tax Act, 2017, by the respondent, Haryana Govt. Excise and Tax Department. The petitioner argued that the authorities failed to adhere to applicable provisions during proceedings, alleged malafide against the officer conducting the CGR (though the officer was not impleaded as a party), and contended that irrelevant observations were made in the show cause notice and the impugned order. The petitioner also claimed the value of goods was enhanced without basis and beyond the officer's purview. The respondent did not present arguments.

Held

The Court held that it would not interfere in the exercise of its jurisdiction under Article 226 of the Constitution of India, as there is an alternate statutory remedy available to the petitioner. Citing the Supreme Court judgments in United Bank Of India vs Satyawati Tandon & Ors., Raj Kumar Shivhare v. Assistant Director, Directorate of Enforcement, and Modern Industries v. Steel Authority of India Limited, the Court reiterated that High Courts should exercise self-imposed restraint and not entertain petitions when a detailed mechanism for redressal of grievances exists within the relevant legislation. The petitioner was unable to demonstrate any exceptional or extraordinary circumstances justifying deviation from the rule of exhausting alternate remedies. All grounds raised by the petitioner were deemed to be within the purview of consideration by the appropriate authority. The petition was dismissed with liberty to the petitioner to avail the alternate remedy.

Key Issues

1. Whether the High Court should entertain a writ petition under Article 226 of the Constitution of India when an alternate statutory remedy is available to the petitioner, as per Section 130 of the Haryana Goods and Services Tax Act, 2017? The petitioner argued that the authorities failed to follow due process, made irrelevant observations, and arbitrarily enhanced the value of goods, thus vitiating the proceedings. They contended these procedural irregularities warranted High Court intervention. The respondent did not present arguments on the merits of the case but relied on the existence of an alternate remedy.