Consequential order cannot survive once the underlying circulars have already been quashed on identical facts.

A consequential order based on circulars already invalidated in an earlier decision cannot survive independently. The Bombay High Court treated the impugned order as part of the same circular-based regime struck down in a similar matter, and quashed and set it aside. The petition was therefore disposed of in favour of the petitioner on the basis that, once the underlying circulars had been annulled on identical facts, the consequential action lacked any continuing legal foundation.

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Issues: Whether the impugned circulars and the consequential order could be sustained when an earlier decision on identical facts had already quashed the circulars.

Analysis: The petition was disposed of in view of the earlier order quashing the same circulars in a similar matter. The impugned order dated 11 December 2018 was treated as consequential to that circular-based regime.

Conclusion: The impugned order was quashed and set aside, and the petition was disposed of in favour of the petitioner.

Final Conclusion: The challenge succeeded on the strength of the earlier decision on the same issue, resulting in annulment of the impugned order.

Ratio Decidendi: Where an earlier binding decision has already invalidated the very circulars forming the basis of the impugned action, the consequential order cannot survive.

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