Natural justice in registration renewal matters bars cancellation or refusal without a hearing, even where alternative remedies exist.

Cancellation or refusal to renew statutory registration without the hearing mandated by the governing law was held unsustainable in writ jurisdiction. The court held that breach of natural justice, particularly the denial of a reasonable opportunity of personal hearing, justified interference despite the availability of an alternative remedy because the action affected the right to carry on business. It also noted that the earlier renewal granted during pending proceedings negatived the claim that the original cancellation had automatically revived. The impugned refusal was set aside and the matter remitted for fresh consideration after hearing.

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Issues: Whether the order cancelling and refusing renewal of the petitioner's registration was valid despite the absence of a prior hearing and the pendency of the petitioner's challenge to the assessment orders.

Analysis: The cancellation and the later refusal to renew the registration were found to have been made without affording a reasonable opportunity of personal hearing, contrary to the statutory requirement of hearing before refusal, cancellation or amendment of registration. The fact that an alternative remedy was available did not bar writ relief where the impugned action violated natural justice and affected the petitioner's right to carry on business. The earlier renewal granted during the pendency of proceedings also negatived the stand that the original cancellation automatically revived so as to justify the later refusal. The respondent was held to have exceeded jurisdiction in treating the registration as unavailable and in refusing renewal without following the prescribed procedure.

Conclusion: The impugned order was unsustainable and was set aside. The respondent was directed to consider the petitioner's renewal representation afresh on merits and in accordance with law after granting a hearing.

Final Conclusion: The writ petition succeeded in assailing the refusal to renew registration, and the matter was remitted for fresh consideration with due hearing to the petitioner.

Ratio Decidendi: An order cancelling or refusing renewal of statutory registration, when passed without the hearing mandated by the governing law, is liable to be quashed in writ jurisdiction notwithstanding the availability of an alternative remedy.

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