Accrued octroi exemptions survive deletion of the rule where prior assurances and sanction show an intent to preserve existing concessions.

A statutory or administrative deletion of an octroi exemption rule was not construed to withdraw concessions already granted to industrialists where the Corporation's representation, resolution and the Government's sanction order showed an intention to preserve existing benefits. The Court treated the order as operating prospectively and held that accrued concessions were not taken away by implication. It also held that the connected writ petition could not be dismissed in limine when additional legal questions remained unanswered; that dismissal was set aside and the matter remitted for fresh disposal according to law.

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Issues: (i) Whether the Government's order deleting the octroi exemption rule could be read as preserving concessions already granted to industrialists under the Corporation's earlier representation and resolution. (ii) Whether the High Court was justified in dismissing in limine the connected writ petition where additional legal questions were involved.

Issue (i): Whether the Government's order deleting the octroi exemption rule could be read as preserving concessions already granted to industrialists under the Corporation's earlier representation and resolution.

Analysis: The exemption scheme arose from the Corporation's own policy and its express assurance that industrialists establishing units in the demarcated area would enjoy octroi exemption for the stipulated period. The Corporation's later resolution recommending deletion of the rule itself preserved the existing concessions. The Government's sanction order expressly referred to that resolution and the Commissioner's letter, and was passed under the statutory scheme governing municipal taxation and governmental sanction of rules. In that context, the order could not be understood as withdrawing accrued concessions or taking away vested rights, particularly when the Government did not return the proposal for reconsideration despite the Corporation's clear condition. The Court also treated the order as requiring a prospective reading consistent with settled principles of statutory interpretation.

Conclusion: The deletion of the rule did not extinguish the concessions already granted, and the respondents' exemption continued.

Issue (ii): Whether the High Court was justified in dismissing in limine the connected writ petition where additional legal questions were involved.

Analysis: The petition raised legal questions beyond the interpretation already decided in the companion matters. In such a situation, a summary dismissal without examination on merits was not appropriate. The matter required reconsideration in light of the legal position declared regarding the Government order and its effect.

Conclusion: The dismissal in limine was set aside and the matter was remitted for fresh disposal according to law.

Final Conclusion: The Court upheld the continued availability of the earlier octroi concessions while sending back the separately dismissed writ petition for reconsideration, thereby leaving the Government's deletion of the rule operative only to the extent consistent with the preserved exemptions.

Ratio Decidendi: A statutory or administrative deletion of a concession-bearing rule will not be construed to divest accrued concessions where the governing order and surrounding resolution show a clear intention to preserve existing grants, and vested rights are not taken away by implication.

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