Statutory appellate remedy must be exhausted first when sales tax disputes turn on contested facts and documents.

Where a statutory appellate remedy is available and the dispute turns on contested facts requiring examination of documents, writ relief is inappropriate until that remedy is exhausted. The assessee had not pursued the appeal under Section 20 of the Karnataka Sales Tax Act, 1957, so the High Court was correct in insisting on recourse to the appellate forum first. The SC held that the Division Bench should not have interfered with the Single Judge's direction to proceed before the first appellate authority, and restored that order, leaving the merits to be decided in the statutory appeal.

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Issues: Whether the assessee was required to exhaust the statutory appellate remedy under Section 20 of the Karnataka Sales Tax Act, 1957 before seeking writ relief, and whether the Division Bench was justified in interfering with the order directing such recourse.

Analysis: The transaction raised disputed questions of fact and required examination of documents, making the statutory appellate forum the appropriate first recourse. The assessee had not availed the appeal provided under Section 20 of the Karnataka Sales Tax Act, 1957, and the High Court was therefore right in insisting on exhaustion of that remedy. The Division Bench ought not to have interfered with the learned Single Judge's order directing the assessee to pursue the appeal remedy.

Conclusion: The assessee was bound to exhaust the statutory appeal remedy, and the direction to pursue appeal under Section 20 of the Karnataka Sales Tax Act, 1957 was upheld.

Final Conclusion: The impugned appellate judgment was set aside and the order requiring the assessee to proceed before the first appellate authority was restored, leaving the merits to be decided in the statutory appeal.

Ratio Decidendi: Where a statutory appellate remedy is available and the dispute turns on contested facts requiring factual adjudication, writ interference is unwarranted until that remedy is exhausted.

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