Collateral challenge to a valid tax-evasion provision failed, with declaratory and injunctive relief refused.

A collateral challenge to section 78 of the Rajasthan Sales Tax Act, 1994 failed because the provision's validity had already been upheld by the Supreme Court and by the High Court in earlier proceedings. The Court held that the Union of India could not use this writ petition to contest the validity of a State enactment in the manner sought, and that the railway administration was expected to cooperate with State authorities in detecting sales tax evasion. Declaratory and injunctive relief was refused, the writ petition was rejected, and the interim directions were continued.

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Issues: Whether section 78 of the Rajasthan Sales Tax Act, 1994 was inapplicable to the railways or liable to be struck down, and whether the petitioners were entitled to restrain the State authorities from acting under that provision.

Analysis: The petition challenged the application and validity of section 78, but the Court held the challenge to be misconceived. The provision's validity had already been upheld by the Supreme Court, and the relevant sub-clauses had also been upheld by the High Court in earlier proceedings. The Court further observed that the Union of India could not challenge the validity of a State enactment in the manner sought and that the railway administration was expected to cooperate with the State in detecting sales tax evasion.

Conclusion: The challenge to section 78 failed and the petitioners were not entitled to the declaratory or injunctive relief sought.

Final Conclusion: The writ petition was rejected, and the interim directions were continued to be operative.

Ratio Decidendi: A statutory provision already upheld as valid cannot be struck down in a collateral challenge of this nature, and the writ remedy will not be used to prevent lawful enforcement measures aimed at detecting tax evasion.

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