Article 226 writ relief unavailable where disputed tax facts required statutory fact-finding machinery instead of writ evidence.

A writ petition under Article 226 was held inappropriate where the core dispute depended on disputed questions of fact, including the claim that relevant sales took place outside the State. The Court noted that such factual controversy could not be resolved satisfactorily in writ proceedings, which do not ordinarily involve evidence, especially when the statute provided an ordinary machinery for factual determination and assessment. Because the East Punjab General Sales Tax Act, 1948 supplied tribunals for deciding those facts and allowed legal questions to reach the High Court, the petitioners were required to use that statutory remedy. The writ petition was therefore dismissed.

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Issues: Whether the writ petition should be entertained under Article 226 of the Constitution of India when the substantial dispute related to disputed questions of fact and the statute provided an ordinary machinery for their determination.

Analysis: The petitioners sought exemption on the footing that the relevant sales took place outside the State, but that factual basis was specifically denied. The dispute could not be satisfactorily resolved without evidence, which is ordinarily not taken in writ proceedings. The East Punjab General Sales Tax Act, 1948 provided tribunals for determining the relevant facts and for assessment on that basis, with provision for legal questions to reach the High Court. In these circumstances, the petitioners were required to pursue the remedy under the statutory machinery instead of invoking the extraordinary jurisdiction of the Court.

Conclusion: The writ petition was not fit for interference under Article 226 and was dismissed.

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