Multiple grounds in cancellation orders fail if one material ground is unsustainable and the remaining ground cannot independently support the result.

An order cancelling a registration certificate under section 7(4) of the Punjab General Sales Tax Act, 1948 could not stand where it rested on two grounds and one material ground was untenable. The alleged sales to bogus dealers was found unsustainable, and the presence of a separate statutory remedy for delay in filing returns under section 10(6) showed that the authority should have proceeded under that provision if delay was the issue. Because it was impossible to say that the valid ground alone would have produced the same result, the cancellation was held not sustainable in law.

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Issues: Whether an order cancelling a registration certificate under section 7(4) of the Punjab General Sales Tax Act, 1948 could be sustained when one of the two grounds relied upon was untenable.

Analysis: The cancellation rested on two grounds, namely alleged sales to bogus dealers and delay in filing the return. The ground relating to bogus dealers was held untenable. Where an authority acts on more than one ground, and one ground is irrelevant or unsustainable, it is not possible to say whether the valid ground alone would have led to the same conclusion. The existence of a separate statutory remedy for delayed return under section 10(6) also showed that the authorities could have proceeded under that provision instead of cancelling the registration certificate under section 7(4).

Conclusion: The cancellation order was not sustainable in law, and the answer to the referred question was in the negative, in favour of the petitioner.

Ratio Decidendi: Where a quasi-judicial or administrative order rests on multiple grounds and one material ground fails, the order cannot be upheld unless it is clear that the remaining ground alone independently supports the result.

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