Promissory estoppel and legitimate expectation cannot bar a public-interest export policy revision withdrawing quota benefits.

The Government may revise or withdraw an export policy in public interest, especially where changed international trade conditions, GATT/ATC obligations, competitiveness concerns, and prevention of misuse justify the shift. In economic and fiscal matters, the executive has wide discretion, and promissory estoppel cannot block a lawful policy change made for public interest. Legitimate expectation likewise does not prevent revision unless the decision is mala fide or an abuse of power. An applicant for export benefits acquires no vested right to insist on continuation of an earlier quota scheme. The revised export policy withdrawing the MEE and NQE quota system was therefore upheld.

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Issues: Whether the Government was bound by its earlier export quota policy so as to be precluded, on principles of promissory estoppel or legitimate expectation, from introducing a revised export policy withdrawing MEE and NQE quotas.

Analysis: The change in the export policy was traced to altered international trade conditions and obligations arising from the GATT/ATC framework, along with the need to improve competitiveness, curb misuse of the earlier quota system, and protect export potential and foreign exchange earnings. In matters of economic and fiscal policy, the executive has wide discretion to revise, withdraw, or replace an earlier policy in public interest. The doctrine of promissory estoppel cannot be invoked to prevent a policy change made in public interest, and legitimate expectation does not fetter the authority where the decision is within the lawful range of executive choice and is neither mala fide nor an abuse of power. An applicant for export benefits acquires no vested right to insist on the continuance of a previous scheme.

Conclusion: The Government was not barred by promissory estoppel or legitimate expectation from revising the export policy and withdrawing the MEE and NQE quota system.

Final Conclusion: The revised export policy was upheld, and the challenge to the notification failed.

Ratio Decidendi: A prior export or import policy does not create a vested right in its continuance, and the Government may alter such policy in public interest unless the change is shown to be mala fide or an abuse of power.

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