Writ jurisdiction cannot bypass statutory tax remedies where factual disputes exist; the raw material definition was upheld as constitutional.

Where a taxing statute provides a complete appellate and revisional mechanism, writ jurisdiction under article 226 should not ordinarily be used to bypass that machinery, particularly when the dispute turns on factual questions such as whether caustic soda was raw material or part of the manufacturing process. The Rajasthan High Court therefore held that the writ petitions were not maintainable in the first instance and that the alternative statutory remedies had to be pursued. It also upheld the definition of "raw material" in section 2(mm), holding that the inclusion of ingredients, fuel and lubricants used in manufacture was neither arbitrary nor violative of article 14. The special appeals failed and the writ dismissal was affirmed.

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Issues: (i) Whether the writ petitions and special appeals could be entertained under article 226 of the Constitution of India despite the statutory appellate and revisional remedies under the Rajasthan Sales Tax Act, 1954. (ii) Whether the definition of "raw material" in section 2(mm) of the Rajasthan Sales Tax Act, 1954 was unconstitutional or otherwise invalid.

Issue (i): Whether the writ petitions and special appeals could be entertained under article 226 of the Constitution of India despite the statutory appellate and revisional remedies under the Rajasthan Sales Tax Act, 1954.

Analysis: The assessment orders were appealable under section 13 of the Rajasthan Sales Tax Act, 1954, with further remedy before the Sales Tax Tribunal under section 14 and revision to the High Court under section 15. The dispute also involved factual questions as to whether caustic soda was a raw material or merely part of the manufacturing process in dyeing and printing. In taxing matters, where a complete statutory machinery exists, writ jurisdiction is not to be used as a short-circuit to bypass those remedies.

Conclusion: The writ petitions were not maintainable in the first instance and the challenge was rightly rejected on the ground of availability of alternative statutory remedies.

Issue (ii): Whether the definition of "raw material" in section 2(mm) of the Rajasthan Sales Tax Act, 1954 was unconstitutional or otherwise invalid.

Analysis: The statutory definition treated as raw material an article used as an ingredient in manufactured goods and also included fuel and lubricant required for the manufacturing process. That classification was held to be neither arbitrary nor unreasonable, and no violation of article 14 of the Constitution of India was made out. The challenge therefore failed on merits.

Conclusion: The definition in section 2(mm) was upheld as valid and constitutional.

Final Conclusion: The special appeals failed in entirety and the dismissal of the writ petitions was affirmed.

Ratio Decidendi: Where an effective statutory appellate and revisional mechanism exists under a taxing statute, writ jurisdiction under article 226 of the Constitution of India should not ordinarily be invoked to bypass that machinery, especially where the controversy turns on disputed questions of fact.

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