Locus standi in concluded tax assessments: a mere complainant cannot reopen final proceedings, and repetitive challenges invite exemplary costs.

A mere complainant, who was neither an assessee nor otherwise legally interested in concluded sales tax assessment proceedings, had no locus standi to reopen or challenge assessments that had already attained finality. The Court also treated repeated litigation over the same controversy, after earlier rejection, as frivolous and vexatious abuse of process. On that basis, the writ petition was dismissed and exemplary costs were imposed for attempting to unsettle concluded proceedings without any enforceable legal right.

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Issues: (i) whether the petitioner, as a complainant and claimed legal representative, had locus standi to challenge the sales tax assessments and subsequent orders; (ii) whether the writ petition was an abuse of process and liable to be dismissed with exemplary costs.

Issue (i): whether the petitioner, as a complainant and claimed legal representative, had locus standi to challenge the sales tax assessments and subsequent orders.

Analysis: The assessments of the firm had already attained finality. The record showed that the petitioner's father was never a partner of the firm, and the petitioner was neither an assessee nor a person having a legal interest in the assessment proceedings. A mere complainant had no enforceable right to reopen concluded tax assessments or to maintain repeated challenges to orders passed in proceedings to which he was not a party.

Conclusion: The petitioner had no locus standi to maintain the challenge.

Issue (ii): whether the writ petition was an abuse of process and liable to be dismissed with exemplary costs.

Analysis: The Court found that the same controversy had already been raised earlier and rejected, yet the petitioner sought to unsettle concluded proceedings without any legitimate basis. The repeated litigation burdened the respondents and the State machinery and served no lawful purpose. In these circumstances, the petition was treated as frivolous and vexatious.

Conclusion: The petition was an abuse of process and warranted dismissal with exemplary costs.

Final Conclusion: The challenge to the concluded sales tax proceedings failed, and the Court imposed costs on the petitioner for vexatious and repetitive litigation.

Ratio Decidendi: A mere complainant, who is neither an assessee nor otherwise legally interested in concluded tax assessment proceedings, lacks locus standi to reopen or challenge those proceedings, and repetitive vexatious litigation amounts to abuse of process warranting exemplary costs.

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