Supreme Court dismisses delayed SPINE scheme claims, no promissory estoppel. Timely legal action crucial.

The Supreme Court dismissed the respondents' claims for financial assistance under the SPINE scheme due to delay and laches, noting that the scheme had been withdrawn. The Court held that promissory estoppel did not apply as there was no promise of benefits after the scheme's closure. Emphasizing the importance of timely legal action, the Court found the respondents' delay unjustified and highlighted the adverse financial impact of granting their belated claims. The appeals were allowed, and the respondents' claims were dismissed without costs.

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Issues Involved:

1. Refusal to sanction financial assistance under the "Scheme of Promotion of Industries in North East" (SPINE) due to delay and laches.
2. Applicability of promissory estoppel.
3. Consistency of judicial decisions regarding the same scheme.
4. Impact of delay and laches on the right to claim benefits.
5. Financial implications on the public exchequer.

Issue-wise Detailed Analysis:

1. Refusal to Sanction Financial Assistance under SPINE Due to Delay and Laches:
The respondents challenged the refusal of financial assistance under SPINE on the grounds of delay and laches. The Guwahati High Court initially dismissed their writ petitions, but this decision was reversed on appeal, directing the implementing authorities to process the applications for investment subsidy under SPINE. The Supreme Court noted that the respondents had delayed their challenge by over two years after the initial decision to stop disbursements was communicated via the letter dated 05-02-2007. The Court concluded that the scheme, SPINE, stood withdrawn with effect from 23-02-2007, and the respondents' claims, by implication, had not been entertained under the scheme.

2. Applicability of Promissory Estoppel:
The respondents argued that they had altered their position based on the promise of financial assistance under SPINE, invoking the doctrine of promissory estoppel. The Supreme Court referenced M/s Motilal Padampt Sugar Mills Co. vs. The State of Uttar Pradesh to explain that promissory estoppel is an equitable doctrine that would yield if equity so required. The Court held that there was no promise from the public functionaries to extend benefits under SPINE after its closure on 23-02-2007, and thus, promissory estoppel was inapplicable in this case.

3. Consistency of Judicial Decisions Regarding the Same Scheme:
The respondents sought parity of treatment with earlier writ petitioners who had successfully challenged the delay in disbursement of SPINE benefits. However, the Supreme Court highlighted that the earlier adjudication did not consider the letter dated 04-05-2010, which confirmed the withdrawal of SPINE effective from 23-02-2007. The Court emphasized that the respondents were aware of the closure of SPINE but chose to delay their legal challenge, thereby disentitling themselves to the benefits of the earlier judgment.

4. Impact of Delay and Laches on the Right to Claim Benefits:
The Supreme Court underscored that delay and laches must be explained with cogent, convincing, and persuasive reasons. The respondents' delay of more than two years in filing their writ petitions was deemed inexcusable. The Court found that the respondents were "fence sitters" who awaited the outcome of the earlier litigation before staking their claim, which was inconsistent with the principles of equity.

5. Financial Implications on the Public Exchequer:
The Supreme Court considered the financial implications of entertaining the respondents' belated claims. The Court noted that granting the respondents' claims would adversely impact the public exchequer and found it inequitable to entertain such delayed claims. The Court emphasized that the doctrine of promissory estoppel should not be applied in a manner that would impose undue financial burdens on the state.

Conclusion:
The Supreme Court set aside the impugned judgment and order, allowing the appeals and dismissing the respondents' claims due to deliberate laches, negligence, and inaction. The Court held that the respondents were not entitled to the benefits under SPINE, which had been withdrawn effective from 23-02-2007. The appeals were allowed without any costs.

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