M/S Akshat Steel vs. State Of Chhattisgarh

Facts

The petitioner, M/s Akshat Steel, filed a writ petition seeking a mandamus to direct respondents to place complete records and to clear an admissible amount of ₹03,50,430/- plus GST, along with interest for any delay. The petitioner also sought any other appropriate relief. The respondents included the State of Chhattisgarh through its Secretary, Department of School Education, the Collector Bilaspur, the Assistant Commissioner (Tribal and Scheduled Caste Development Department), Bilaspur, and the Chhattisgarh State Industrial Development Corporation Limited. 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 16.06.2025.

Held

The Court held 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 relief sought by the petitioner was contingent upon the resolution of disputed questions of fact, which cannot be adjudicated under Article 226. Therefore, it would not be appropriate for the Court to entertain the writ petition. The Court noted that the facts and issues in the present case are identical to WPC No. 2870/2025, which was dismissed on 16.06.2025. Consequently, the present petition was dismissed in the same terms as the previous order. The Court explicitly stated that the writ petition was devoid of merit and dismissed it, reserving liberty 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 jurisdiction under Article 226 of the Constitution of India when disputed questions of fact are involved. Petitioner's Argument: The petitioner sought a writ of mandamus and certiorari to direct the respondents to clear an admissible amount and provide interest, implying a need for the court's intervention. Revenue/State's Argument: The respondents, through their counsel, referred to the dismissal of an identical writ petition (WPC No. 2870/2025) by the same Bench. They argued that the facts and issues in the present case are identical to the dismissed petition, which was dismissed on the grounds that disputed questions of fact cannot be adjudicated under Article 226. They relied on the reasoning in the previous order, which cited well-settled propositions of law regarding the limitations of writ jurisdiction in cases involving disputed facts.