Facts of the Case
The petitioner, Omprakash Loya, was carrying on
business through Omprakash Loya and Company and claimed to be engaged in
the lawful trade of jaggery under a valid licence and registration. The
petitioner alleged that the respondent Excise and Police authorities were
interfering with his business activities, including the business in black jaggery
and alum, despite the production of bills and way bills evidencing lawful
purchase and transportation of the goods.
The petitioner further complained of seizure of jaggery and
alum and interference with the vehicle bearing Registration No. AP-15-TC-0660.
According to the petitioner, such interference prevented him from carrying on a
lawful business and was illegal, arbitrary and unsupported by any authority of
law.
Accordingly, the petitioner invoked the writ jurisdiction of
the High Court under Article 226 of the Constitution of India, seeking a
writ of mandamus against unlawful interference, harassment and seizure.
When the matter came up for hearing, the petitioner submitted
that the issue raised in the writ petition was squarely covered by the
Telangana High Court’s earlier orders in:
- W.P.
No. 31519 of 2016, decided on 19.04.2022; and
- W.P.
No. 1677 of 2016, decided on 26.07.2022.
The learned Government Pleader for Prohibition and Excise did
not dispute this submission.
Issues Involved
The principal issues arising from the case were:
- Whether
Excise and Police authorities could interfere with a trader’s lawful
business in jaggery, black jaggery and alum merely because such
commodities might potentially be used in the manufacture of illicitly
distilled liquor.
- Whether
seizure of jaggery, alum, business stocks or a transport vehicle could be
sustained without specific legal authority and without compliance with due
process.
- Whether
the mere possession, storage, purchase, sale or transportation of black
jaggery could justify coercive action when such trade was not otherwise
prohibited by law.
- Whether
authorities could interfere with a validly licensed and registered
business despite the production of bills, invoices or way bills supporting
lawful transactions.
- Whether
such interference violated the constitutional guarantees under Articles
14, 19(1)(g) and 21 of the Constitution of India.
- Whether
action under the GUR (Regulation of Use) Order, 1968, particularly
in the context of Rule 5, required lawful grounds and procedural
compliance before adverse action could be taken.
Petitioner’s Arguments
The petitioner contended that he was conducting a lawful
business in jaggery under a valid licence and registration issued by the
competent authorities.
It was argued that the goods had been purchased under proper
bills and transported under way bills, and therefore the respondents had no
authority to seize the stocks or interfere with the business merely on
suspicion.
The petitioner maintained that black jaggery and alum were
not, by themselves, prohibited commodities or contraband. Consequently, lawful
possession, storage, sale and transportation could not automatically be treated
as illegal.
The petitioner further contended that arbitrary interference
by the authorities with a legally permitted business amounted to an
infringement of the constitutional right to carry on trade or business and was
contrary to due process of law.
At the time of final hearing, the petitioner specifically
relied upon the orders in W.P. No. 31519 of 2016 and W.P. No. 1677 of
2016, submitting that the controversy was fully covered by those decisions.
Respondents’ Arguments
The learned Government Pleader for Prohibition and Excise
appeared on behalf of the respondents.
In the present writ petition, the submission that the issue
was covered by the earlier orders dated 19.04.2022 and 26.07.2022
was not disputed.
The broader stand of the authorities, as reflected in the
related cases annexed to the order, was based on the State’s objective of
eradicating the manufacture and sale of illicitly distilled liquor and
preventing diversion of black jaggery as a raw material for such illegal
manufacture.
In the related proceedings, the authorities had also sought to
justify raids, searches and seizures on grounds such as non-production of bills
or way bills, storage of substantial quantities of black jaggery, and suspected
supply to persons engaged in illicit liquor manufacture.
However, the Court’s related rulings emphasized that a
legitimate policy objective to eradicate illicit liquor does not, by itself,
confer unrestricted authority to interfere with an otherwise lawful trade.
Court Order / Findings
The High Court recorded that the petitioner’s counsel had
submitted that the issue was squarely covered by the earlier orders in W.P.
No. 31519 of 2016 dated 19.04.2022 and W.P. No. 1677 of 2016 dated
26.07.2022.
The Court further recorded that this submission was not
disputed by the learned Government Pleader appearing for the respondents.
Accordingly, the High Court disposed of the writ petition and
directed the respondents to follow the directions contained in the earlier
orders passed in those two writ petitions.
The Court imposed no order as to costs and directed
that pending miscellaneous petitions, if any, should stand closed.
The Registry was also directed to annex copies of the orders
passed in the two related writ petitions to the present order.
Important Clarification
The present judgment must be read together with the two
earlier orders expressly adopted by the High Court. The legal position emerging
from those decisions is significant:
First, the manufacture and sale of
black jaggery or jaggery by traders was held not to be prohibited merely by
reason of the commodity itself.
Second, black jaggery had been
recognized in Government Memo No. 47802/Ex.III.1/2006-13 dated 20.12.2010
as an agricultural produce or its bio-product.
Third, a person conducting a business
permitted by law cannot be subjected to raids, coercive interference, seizure
or forced closure merely because the State has adopted a policy to eradicate
illicitly distilled liquor.
Fourth, powers of entry, inspection,
search and seizure under the GUR (Regulation of Use) Order, 1968 must be
exercised within the limits of law and on the existence of legally relevant
grounds.
Fifth, in the related W.P. No. 1677 of
2016, the Court clarified that mere possession of 7,480 kg of jaggery
would not by itself justify action unless the trader failed to produce purchase
invoices when lawfully required to do so.
Sixth, the Court clarified that under
the applicable VAT framework, way bills were required in the context explained
by the Court and could not mechanically be demanded for every retail
transaction.
Seventh, in the absence of material
showing issuance of notice under Rule 5 of the GUR (Regulation of Use)
Order, 1968 calling upon the trader to furnish particulars of purchases and
sales with supporting bills or invoices, a mere allegation of storing large
quantities of black jaggery or not producing way bills was insufficient.
Eighth, interference with lawful
business without authority of law was held in the related proceedings to offend
Articles 14, 19(1)(g) and 21 of the Constitution of India.
Ninth, the State’s objective of
eradicating illicitly distilled liquor, however legitimate, does not permit
authorities to bypass due process or presume that every sale of black jaggery
is intended for illegal liquor manufacture.
Related Case Law in Detail
1. W.P. No. 31519 of 2016 – Telangana High Court,
decided on 19.04.2022
This was the principal precedent relied upon in the present
matter.
The Court held that manufacture and sale of black jaggery and
jaggery by manufacturers or traders was not prohibited under the law in
Telangana. The petitioner in that case was a registered dealer carrying on
business in jaggery.
The authorities contended that regular raids were being
conducted pursuant to governmental instructions aimed at eradicating illicitly
distilled liquor and preventing supply of black jaggery for its manufacture.
The High Court rejected any proposition that the State’s
policy objective, by itself, created unrestricted power to enter business
premises, search, inspect, seize documents or coerce a trader to stop selling
black jaggery.
The Court held that where a trader carries on a legally
permitted business under valid permissions and registrations, authorities
cannot interfere merely on a generalized assumption that black jaggery may be
used for illicit liquor manufacture.
The Court further held that, in the absence of material
showing involvement of the trader in manufacture of illicit liquor or showing
that the stored black jaggery was intended for such manufacture, lawful sales
to buyers could not automatically make the trader an accomplice.
The writ petition was allowed, and the authorities were
directed not to interfere with the petitioner’s life, liberty and lawful trade
except in accordance with law or until such activity was otherwise prohibited
by the State.
2. W.P. No. 1677 of 2016 – Telangana High Court,
decided on 26.07.2022
In this related case, the petitioner was a registered trader
dealing in jaggery. The authorities had seized 7,480 kg of jaggery and
relied, among other things, on alleged non-production of relevant documents.
The Court held that mere possession of a large quantity of
jaggery did not, by itself, justify adverse action. The Court examined the
distinction concerning production of way bills and purchase invoices and
emphasized the requirement of lawful procedure.
The Court noted the absence of material showing that the
authorities had called upon the petitioner to produce relevant purchase and
sale documentation and that the petitioner had failed to comply.
It was further held that, in the absence of notice under Rule
5 of the GUR (Regulation of Use) Order, 1968, the authorities could not
justify interference merely on the allegation that a large quantity of black
jaggery was stored or that way bills were not produced.
The Court concluded that the raid and seizure amounted to
interference with lawful business and contravened Articles 14, 19(1)(g) and
21 of the Constitution of India. A writ of mandamus was issued restraining
unlawful interference except in accordance with law.
3. Ganesh Traders (Kirana and General Merchants),
Dharmapuri, Karimnagar District vs District Collector, Karimnagar and Others –
Full Bench
The respondents relied upon the Full Bench decision reported
as 2002 (1) ALD 210 (FB).
However, in W.P. No. 31519 of 2016, the Telangana High Court
distinguished that decision on facts. The Court noted that in Ganesh Traders,
there was specific material, including circumstances giving rise to a
reasonable belief that black jaggery was intended for manufacture of illicitly
distilled liquor and a Chemical Examiner’s report concerning fitness for human
consumption.
By contrast, where no comparable material exists linking the
trader or the goods to illicit liquor manufacture, the Full Bench ruling cannot
be mechanically invoked to justify interference with lawful trade.
Sections / Constitutional Provisions / Legal
Instruments Involved
Article 226 of the Constitution of India – Writ
jurisdiction of the High Court.
Article 14 of the Constitution of India –
Protection against arbitrary State action and guarantee of equality before law.
Article 19(1)(g) of the Constitution of India – Right
to practise any profession or carry on any occupation, trade or business,
subject to lawful restrictions.
Article 21 of the Constitution of India –
Protection of life and personal liberty except according to procedure
established by law.
Section 34(e) of the A.P. Excise Act, 1968 –
Referred to in the connected proceedings concerning alleged offences associated
with illicit liquor-related activities.
Rules 4 and 5 / Rule 5 of the GUR (Regulation of
Use) Order, 1968 – Relevant to regulation, calling for particulars
and the lawful exercise of powers in relation to gur or jaggery where misuse is
suspected.
A.P. Value Added Tax Act, 2005 / Telangana Value
Added Tax framework – Relevant in the connected case concerning
registered dealers, invoices, way bills and lawful trade transactions.
Government Memo No. 47802/Ex.III.1/2006-13 dated 20.12.2010 – Referred to for recognition of black jaggery as an agricultural produce or its bio-product.
Link to download the order -https://mytaxexpert.co.in/uploads/1783668428_3054compressed.pdf
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