M/S Akshat Steel vs. State Of Chhattisgarh

Facts

The petitioner, M/s Akshat Steel, through its proprietor, filed a writ petition seeking a mandamus to direct respondents 2 and 3 (Assistant Commissioner and Collector, Tribal and Scheduled Caste Development Department) to clear an admissible amount of ₹22,73,380/- plus GST, along with interest as per the rate contract. The petitioner also sought a direction to place the complete record for proper decision. The respondents, including the State and Chhattisgarh State Industrial Development Corporation Limited, were also parties. The petitioner and respondents pointed out that an identical matter, WPC No. 2870/2025 (M/s Sai Info Services vs. State of Chhattisgarh & Others), was dismissed by the same bench on June 16, 2025.

Held

The Court held that it is a well-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, as the remedy under Article 226 may not be proper. In the present case, the relief sought by the petitioner is contingent upon the resolution of disputed questions of fact, which cannot be adjudicated under Article 226. Therefore, the Court found it inappropriate to entertain the writ petition. The Court explicitly referred to its previous order in WPC No. 2870/2025, which dismissed the petition on similar grounds, citing Supreme Court judgments. The ratio decidendi is that writ jurisdiction is not the appropriate forum for resolving disputes involving factual controversies. The petition was dismissed, with liberty reserved for the petitioner to pursue alternate remedies.

Key Issues

1. Whether the High Court should exercise its writ jurisdiction under Article 226 of the Constitution of India when disputed questions of fact are involved. Petitioner's Argument: The petitioner sought a mandamus for the clearance of an admissible amount and interest, implying a contractual obligation and a clear entitlement. The petitioner's counsel argued for the issuance of appropriate writs to direct the respondents to clear the amount and provide the record. Revenue/State's Argument: The respondents, through the Additional Advocate General, along with counsel for respondent No. 4, submitted that the facts and issues in the present case are identical to WPC No. 2870/2025. They argued that in the cited case, the Court held that when disputed questions of fact are involved, the High Court should not exercise its jurisdiction under Article 226, as the remedy under Article 226 may not be proper. They contended that the relief sought is contingent upon the resolution of disputed facts, which cannot be adjudicated under Article 226.