M/S Smriti Enterprises vs. State Of Chhattisgarh

Facts

The petitioner, M/s Smriti Enterprises, a supplier of school uniforms and general order supplies, filed a writ petition seeking a mandamus to release an outstanding payment of ₹33,51,950/- plus GST. The petitioner had supplied diapers, doormats, baby cloth, and curtains to respondents No. 2 and 3 based on purchase orders dated July 28, 2023, and July 31, 2023. The goods were inspected and delivery receipts were issued. Despite repeated oral and written representations between 2023 and 2025, the payment remained uncleared, causing financial strain. The respondents argued that the writ petition was not maintainable due to disputed questions of fact.

Held

The Court held that it is a settled proposition of law that when disputed questions of fact are involved, the High Court should not exercise its jurisdiction under Article 226 of the Constitution of India. The remedy under Article 226 may not be proper in such circumstances. The Court found that the petitioner's prayer for a direction to release pending dues was contingent upon the resolution of disputed questions of fact, which could not be adjudicated in a writ petition. Citing judgments from the Supreme Court, including Chairman, Grid Corporation of Orissa Ltd. v. Sukamani Das, S.P.S. Rathore v. State of Haryana, Shubhas Jain v. Rajeshwari Shivam, Union of India v. Puna Hinda, and M.P. Power Management Co. Ltd. v. Sky Power Southeast Solar India (P) Ltd., the Court concluded that it would not be appropriate to entertain the writ petition due to the presence of disputed facts. The writ petition was dismissed, with liberty reserved for the petitioner to pursue alternate remedies.

Key Issues

1. Whether the High Court should entertain a writ petition under Article 226 of the Constitution of India when disputed questions of fact are involved, particularly concerning contractual claims for payment. The petitioner contended that official acts are presumed to be regularly performed, and having fulfilled all supply conditions, the respondents were legally obligated to release the legitimate claim. They argued that their repeated representations were ignored without justification. The respondents argued that the writ petition was not maintainable as the disputed questions of fact could not be adjudicated in writ proceedings under Article 226 of the Constitution of India.