Statutory fee collection through an administrative channel upheld, but quid pro quo for the levy itself required reconsideration.

The Board's authority to collect infrastructure development charges through the metropolitan development authority was upheld because the rate had already been fixed by the statutory body and the collection arrangement was treated as an administrative mechanism, not an impermissible delegation of levy power. The challenge to the levy itself, however, required reconsideration because a fee must show a fair correlation with the services rendered, and the record did not disclose the basis for the rate or the link between the charge and water supply and sewerage infrastructure. The validity of the levy on the principle of quid pro quo was therefore left open for fresh consideration on remand.

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Issues: (i) whether the Chennai Metropolitan Water Supply and Sewerage Board could authorise the Chennai Metropolitan Development Authority to collect infrastructure development charges from applicants for multistoreyed and special buildings, and (ii) whether the levy of infrastructure development charges was justified on the principle of quid pro quo.

Issue (i): Whether the Chennai Metropolitan Water Supply and Sewerage Board could authorise the Chennai Metropolitan Development Authority to collect infrastructure development charges from applicants for multistoreyed and special buildings.

Analysis: The power to levy and collect charges had to be traced to the parent statute. The Board was a statutory body and could delegate only to the extent permitted by the Act. The Court distinguished between substantive delegation of power and the manner of collection. Since the rate had already been fixed by the Board and the regulation only enabled collection through CMDA as an administrative mechanism, the arrangement was treated as a matter of procedure and not an impermissible delegation of statutory power.

Conclusion: The collection of infrastructure development charges through CMDA was upheld.

Issue (ii): Whether the levy of infrastructure development charges was justified on the principle of quid pro quo.

Analysis: A fee must bear a fair correspondence to the services rendered, though not mathematical exactitude. The material before the authorities did not disclose the basis for fixing the rate or the correlation between the amount collected and the services to be provided for water supply and sewerage infrastructure. In the absence of supporting material, the challenge to the levy could not be finally rejected, and the matter required reconsideration with an opportunity to place justification on record.

Conclusion: The issue of validity of the levy on the principle of quid pro quo was left open for fresh consideration on remand.

Final Conclusion: The administrative mode of collection was sustained, but the challenge to the levy itself required reconsideration for want of material establishing the necessary correlation between the charge and the service.

Ratio Decidendi: A statutory fee must rest on a demonstrable fair correlation between the levy and the service rendered, and a collection mechanism that merely channels an already fixed charge may be treated as procedural rather than as an invalid delegation of power.

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