Essential commodities control measures and stock limits: regulatory restrictions upheld, while seizure disputes were left to statutory proceedings.

Regulatory teleprinter instructions and an amended stock-limit order were treated as executive measures aimed at controlling essential commodities, preventing hoarding and black-marketing, and ensuring equitable distribution at fair prices. The measures were described as having a rational nexus with public distribution and price support, and as imposing reasonable restrictions consistent with Articles 14, 19(1)(g) and 301. On the seizure challenge, the text notes that relief under Article 32 was inappropriate because the dispute turned on contested facts about the source and movement of the wheat, which were already before the statutory confiscation authority under Section 6A of the Essential Commodities Act, 1955.

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Issues: (i) Whether the State Government's teleprinter instructions and the amended stock-limit order constituted valid regulatory measures and reasonable restrictions, and did not violate the freedoms under Articles 14, 19(1)(g) and 301 of the Constitution. (ii) Whether the seizure of wheat could be assailed under Article 32 as deprivation of property without authority of law, notwithstanding the pending confiscation proceedings under Section 6A of the Essential Commodities Act, 1955.

Issue (i): Whether the State Government's teleprinter instructions and the amended stock-limit order constituted valid regulatory measures and reasonable restrictions, and did not violate the freedoms under Articles 14, 19(1)(g) and 301 of the Constitution.

Analysis: The teleprinter message was treated as executive instructions intended to secure observance of the control orders and to ensure verification of movement of wheat at check-posts. The stock-limit amendment fixing the maximum quantity that wholesale dealers, commission agents, and retailers could hold was directed to prevent hoarding, black-marketing, and speculative cornering of wheat, and to secure equitable distribution and availability at fair prices. Such measures were held to be regulatory in character and supported by the State's executive power in a field where the legislature could validly legislate. The restrictions were found to have a rational nexus with the object of public distribution and price support, and were not arbitrary or excessive.

Conclusion: The measures were upheld as valid and reasonable restrictions, and no violation of Articles 14, 19(1)(g) or 301 was found.

Issue (ii): Whether the seizure of wheat could be assailed under Article 32 as deprivation of property without authority of law, notwithstanding the pending confiscation proceedings under Section 6A of the Essential Commodities Act, 1955.

Analysis: The entitlement to relief depended on disputed questions of fact, including whether the wheat had been purchased in Delhi or in Uttar Pradesh and whether the movement was in genuine inter-State transit or in contravention of the control orders. Those questions were already before the statutory authority under Section 6A. The Court declined to determine the factual controversy in writ proceedings under Article 32 and held that the appropriate course was for the petitioners to establish their case in the pending confiscation proceedings, with any further remedy lying elsewhere if necessary.

Conclusion: No relief was granted under Article 32 on the seizure-related challenge.

Final Conclusion: The impugned State measures were sustained as regulatory and lawful, and the writ petitions failed because the seizure disputes turned on unresolved facts to be decided in the pending statutory proceedings.

Ratio Decidendi: Regulatory measures adopted in the public interest to control essential commodities and prevent hoarding or black-marketing are valid if they are reasonable and non-arbitrary, and disputed factual controversies over seizure and contravention should ordinarily be resolved in the prescribed statutory forum rather than in writ jurisdiction.

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