Writ jurisdiction and alternative remedy limit interference where reassessment disputes can be pursued through the statutory appellate scheme.

Article 226 relief is ordinarily declined where the taxing statute provides a complete appellate hierarchy and the assessee has already pursued that remedy. The High Court should interfere only in exceptional cases such as a jurisdictional defect, challenge to vires, breach of natural justice, or a patent error causing grave injustice. A merely wrong interpretation of the charging provision does not by itself strip the assessing authority of jurisdiction. On that basis, writ interference was not appropriate because the statutory remedy was available and already availed, and no exceptional ground was shown.

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Issues: Whether the High Court should entertain writ petitions challenging reassessment orders when the assessees had already pursued the statutory appeals, and whether the alleged wrong interpretation of the charging provision amounted to absence of jurisdiction.

Analysis: Article 226 confers wide discretionary power, but that power is ordinarily exercised with restraint where the statute provides a complete remedial scheme including appeal and further reference. The existence of an adequate alternative remedy is a strong reason to decline interference unless there is a jurisdictional defect, a challenge to vires, a breach of natural justice, or a patent error causing grave injustice. A mere erroneous interpretation of a provision by an assessing authority does not by itself convert an otherwise competent exercise of jurisdiction into lack of jurisdiction.

Conclusion: The petitions were not fit for interference under Article 226, because the assessees had an available and already availed statutory remedy and no exceptional ground was made out; the challenge based on wrong interpretation did not establish want of jurisdiction.

Ratio Decidendi: Where a taxing statute provides an effective hierarchy of remedies, the High Court should ordinarily decline writ interference unless the case discloses a jurisdictional defect, constitutional challenge, breach of natural justice, or other exceptional circumstance justifying bypass of the statutory remedy; an erroneous decision on the merits within jurisdiction is not a jurisdictional error.

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