M/S Akshat Steel vs. State Of Chhattisgarh

Facts

The petitioner, M/s Akshat Steel, through its proprietor Akshat Agrawal, filed a writ petition seeking a mandamus to direct the respondents to place the complete record and to clear an admissible amount of ₹16,15,516/- plus GST, along with interest for any delay, as per a rate contract. The respondents are the State of Chhattisgarh through its Secretary, Department of School Education, the Collector Bilaspur (Tribal and Scheduled Caste Development Department), the Assistant Commissioner (Tribal and Scheduled Caste Development Department) Bilaspur, and the Chhattisgarh State Industrial Development Corporation Limited. The petitioner sought these directions from the High Court under Article 226 of the Constitution of India.

Held

The Court held that it is a well-settled proposition of law that when disputed questions of fact are involved in a case, 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. The Court noted that the relief sought by the petitioner was contingent upon the resolution of disputed questions of fact, which could not be adjudicated under Article 226. Therefore, it would not be appropriate for the Court to entertain the writ petition. Citing its own previous order in an identical matter (WPC No. 2870/2025), the Court found no good ground to entertain the present writ petition. The petition was dismissed as being devoid of merit, with liberty reserved for the petitioner to pursue other alternate remedies available under the law. No costs were awarded.

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 in the matter? (Question of law) Petitioner's Argument: The petitioner sought a writ of mandamus and certiorari to direct the respondents to release an admissible amount of ₹16,15,516/- plus GST and to provide interest as per the rate contract. The petitioner implicitly argued that the court should intervene to ensure the payment of the admitted amount. Revenue/State's Argument: The respondents, through their counsel, 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 16.06.2025. They argued that the facts and issues in the present case are identical to the previously dismissed petition, and therefore, this petition should also be dismissed on the same grounds. The respondents' argument hinges on the principle that writ jurisdiction is not appropriate for resolving disputed facts.