Detention notice challenge turned infructuous after release of goods, while pending composition proceedings were ordered to be completed expeditiously.

The detention notice challenge became infructuous once the goods were released on payment of the disputed tax, leaving no surviving grievance on that issue. However, because the composition proceedings had not yet been finalised, the HC directed the respondent to complete those proceedings expeditiously, preferably within two weeks of receipt of the order. The writ petition was thus disposed of with the principal challenge treated as infructuous and with a time-bound direction for early completion of the pending composition proceedings.

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Issues: (i) Whether the challenge to the goods detention notice survived after release of the goods on payment of the disputed tax; (ii) whether a direction could be issued for expeditious completion of the composition proceedings.

Issue (i): Whether the challenge to the goods detention notice survived after release of the goods on payment of the disputed tax.

Analysis: The goods had already been released after payment of the disputed tax, and no subsisting grievance remained in relation to the detention notice.

Conclusion: The challenge to the impugned detention notice had become infructuous.

Issue (ii): Whether a direction could be issued for expeditious completion of the composition proceedings.

Analysis: Since the composition proceedings had not been finalised, a direction was warranted to ensure prompt completion of the pending proceedings.

Conclusion: The respondent was directed to complete the composition proceedings expeditiously, preferably within two weeks from receipt of the order.

Final Conclusion: The writ petition was disposed of with the principal challenge rendered infructuous and with a direction for early completion of the composition proceedings.

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