Locus standi in writ jurisdiction and rational tax exemption limits upheld where the measure curbs tax evasion.

A writ petition under Article 226 was found not maintainable because a society representing members with a common commercial interest is not, by that fact alone, a person personally aggrieved. The court also treated the modified exemption under Section 17 of the Tamil Nadu General Sales Tax Act as valid, since it was aimed at curbing malpractice and tax evasion and had a rational basis linked to lawful revenue protection. The restriction on an earlier tax privilege was therefore not considered arbitrary or purposeless, and the tax-related modification was upheld.

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Issues: (i) whether the petitioner society had locus standi as an aggrieved person to invoke Article 226 of the Constitution of India; (ii) whether the modified exemption under Section 17 of the Tamil Nadu General Sales Tax Act was arbitrary or purposeless.

Issue (i): whether the petitioner society had locus standi as an aggrieved person to invoke Article 226 of the Constitution of India.

Analysis: The remedy under Article 226 is available to a person who is personally aggrieved or affected. A society registered under the Societies Registration Act, representing members with a common commercial interest, is not by that circumstance alone a personally aggrieved person for invoking writ jurisdiction. The objection went to the maintainability of the petition.

Conclusion: The petitioner society lacked locus standi to maintain the writ petition.

Issue (ii): whether the modified exemption under Section 17 of the Tamil Nadu General Sales Tax Act was arbitrary or purposeless.

Analysis: The modification was introduced to curb malpractices and prevent evasion of tax in the trade. The measure had a rational basis linked to the objective of non-evasion of lawful tax and could not be characterised as capricious or arbitrary merely because the earlier privilege was conditioned or withdrawn.

Conclusion: The modified exemption was not arbitrary or purposeless.

Final Conclusion: The writ challenge failed both on maintainability and on merits, and the impugned tax-related modification was upheld.

Ratio Decidendi: Writ relief under Article 226 is available only to a person personally aggrieved, and a tax-related exemption measure adopted to prevent evasion of lawful tax is not arbitrary merely because it restricts a previously enjoyed privilege.

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