M.Manikanda Prabhu vs. The Government Of Tamil Nadu

Facts

The petitioner, M. Manikanda Prabhu, filed a writ petition before the Madurai Bench of the Madras High Court challenging an order dated 17.11.2025 passed by the Assistant Commissioner (ST), Thirupparankundram (second respondent). The petitioner sought to quash this order and direct the respondent to drop all further proceedings. The respondents included the Government of Tamil Nadu, the Assistant Commissioner (ST), the Deputy Commercial Tax Officer, and the Commissioner, Thirupparankundram Panchayat Union. The writ petition was filed under Article 226 of the Constitution of India. The tax period in dispute is not explicitly mentioned, nor is the specific amount in dispute.

Held

The Court noted that the Additional Government Pleader for the official respondents submitted that the impugned order dated 17.11.2025 had been withdrawn by an order dated 06.01.2026. Since the impugned order, which was the subject of the challenge, was withdrawn, the prayer sought by the petitioner in the writ petition became infructuous. Consequently, the Court held that the writ petition stood dismissed as infructuous. The reasoning is based on the fact that the action being challenged no longer existed. The operative direction was to dismiss the writ petition as infructuous and close the connected miscellaneous petitions. No issue was expressly left undecided.

Key Issues

1. Whether the impugned order passed by the second respondent, dated 17.11.2025, is illegal, arbitrary, and without jurisdiction, warranting its quashing under Article 226 of the Constitution of India? The petitioner argued that the order was illegal, arbitrary, and without jurisdiction. The respondents, represented by the Additional Government Pleader, submitted that the impugned order dated 17.11.2025 had been withdrawn by virtue of a subsequent order dated 06.01.2026. No specific provisions of the GST Act or Rules were explicitly cited by either party in the arguments presented before the court.