Writ review of factual findings is limited where financial disclosure for excise settlement was incomplete and source of funds remained unproved.

Full disclosure of financial capacity and sources of finance was required under the Assam Excise Rules, 1945, and those disclosures were open to verification when settlement of an excise shop was sought. The Board treated the appellant's failure to disclose the relevant bank account and to produce the pass book as showing that the claimed source of funds was not bona fide. That assessment was a finding of fact, and writ review was limited to jurisdictional error, absence of evidence, or breach of natural justice. Minor omissions in the Board's reasoning did not convert the matter into an error of law, because the material still did not establish a bona fide source for the payment.

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Issues: Whether the High Court could interfere under Article 226 of the Constitution of India with the Board's finding that the appellant lacked the necessary financial capacity for settlement of the excise shop and that the source of funds used to take possession was not bona fide.

Analysis: The settlement application under the Assam Excise Rules, 1945 required full disclosure of financial capacity and sources of finance, which were subject to verification. The appellant had not disclosed the relevant bank account from which part of the payment was allegedly made, and had also not produced the pass book before the Board. The Board's conclusion was therefore a finding of fact based on the material before it. A writ court does not function as an appellate court over a domestic tribunal and may interfere only where there is a jurisdictional error or a finding is wholly unsupported by evidence or vitiated by a violation of natural justice. Although the Board did not expressly record every possible inferential finding and did not discuss one letter in detail, those omissions did not convert the decision into an error of law because the material still did not establish a bona fide source for the full amount paid.

Conclusion: The Board's finding was not open to interference in writ jurisdiction and the challenge to the settlement failed.

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