Alternative statutory remedy and limited review jurisdiction can bar writ interference and reopening of decided facts.

An efficacious statutory alternative remedy can justify refusal of writ relief under Article 226, particularly where the challenge is brought after considerable delay and no sufficient ground for discretionary interference is shown. The text also states that review jurisdiction is narrow: it cannot be used to reappraise the same facts or rehear the merits unless there is an error apparent on the face of the record. On that basis, the writ challenge was not entertained and the review application was held to be outside the permissible scope of review.

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Issues: (i) whether the writ petition under Article 226 was maintainable in view of the petitioner's efficacious alternative remedy under section 45 of the Delhi Sales Tax Act, 1975 and the delay in approaching the Court; (ii) whether the Sales Tax Tribunal was justified in dismissing the review application as an attempt to reappraise the same facts beyond the limited scope of review.

Issue (i): whether the writ petition under Article 226 was maintainable in view of the petitioner's efficacious alternative remedy under section 45 of the Delhi Sales Tax Act, 1975 and the delay in approaching the Court.

Analysis: The petitioner had a statutory remedy by way of reference to the High Court against the Tribunal's order but did not avail it. The challenge was brought after considerable delay, and no sufficient ground was shown to justify interference in writ jurisdiction. The existence of an effective alternative remedy and the belated approach weighed against the exercise of discretionary writ jurisdiction.

Conclusion: The writ petition was not entitled to interference on this ground and the objection to maintainability succeeded against the petitioner.

Issue (ii): whether the Sales Tax Tribunal was justified in dismissing the review application as an attempt to reappraise the same facts beyond the limited scope of review.

Analysis: The review application did not disclose any error apparent on the face of the record. It sought a fresh appraisal of the same facts already considered in the appeal. The limited jurisdiction of review does not permit rehearing on merits or reconsideration of concluded factual findings.

Conclusion: The Tribunal correctly dismissed the review application, and no infirmity was found in that order.

Final Conclusion: The Court declined to interfere with the impugned orders, holding that the petitioner had an alternative statutory remedy and that the review was outside the permissible scope of review jurisdiction.

Ratio Decidendi: Where an efficacious statutory remedy is available and the challenge is belated, writ relief may be refused; review cannot be used to reopen or reargue facts already adjudicated.

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