Civil court summons power survives tax confidentiality under section 57; departmental records may still be produced in civil suits.

Section 57 of the Tamil Nadu General Sales Tax Act, 1959, protects the confidentiality of particulars in statements, returns, accounts and records produced under the Act and restrains disclosure by departmental , but it does not by express words or necessary implication bar a civil court from summoning relevant documents or witnesses from the commercial tax department. The reference in section 57(2)(iv) to disclosure to a civil court was treated as an enabling safeguard rather than an exhaustive limitation on civil court powers. The construction favouring the court's summons power was preferred, and the contrary view was rejected, so the applications for production were rightly allowed.

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Issues: Whether section 57 of the Tamil Nadu General Sales Tax Act, 1959, bars a civil court from summoning documents and witnesses from the commercial tax department in aid of a civil suit.

Analysis: Section 57 makes particulars contained in statements, returns, accounts, records and documents produced under the Act confidential and prohibits disclosure by the departmental authorities. The provision, however, contains no express words fettering the power of a civil court to require production of such documents. A court's power can be curtailed only by clear statutory language or necessary implication, and no such restriction is found in section 57. The reference to disclosure to a civil court in section 57(2)(iv) was treated as an enabling and abundant-caution provision, not as an exhaustive statement that excludes all other civil suits. The earlier view taking the same construction was preferred, while the contrary view that the court itself could not summon the documents was rejected.

Conclusion: Section 57 does not prohibit a civil court from issuing summons for production of documents in the custody of the commercial tax department, and the applications were rightly allowed.

Ratio Decidendi: A statutory confidentiality clause that regulates disclosure by departmental does not, without express words or necessary implication, restrict the power of a civil court to summon relevant documents.

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