Alternative remedy rule bars writ challenges to tax assessment orders when statutory appeal and revision remedies are available.

Where a special tax statute provides appeal, revision and rectification against assessment orders, writ jurisdiction should ordinarily not be invoked unless a recognised exception to the rule of alternative remedy is shown. Applying that principle to assessment orders under the Tamil Nadu Value Added Tax Act, 2006, the High Court noted the existence of a complete statutory remedial framework and held that the writ appeals were not maintainable because the assessee had not exhausted those remedies. The dismissal of the writ petitions was therefore upheld.

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Issues: (i) Whether the writ appeals challenging assessment orders were maintainable when the statute provided effective appellate and revisional remedies.

Analysis: The assessment orders arose under the Tamil Nadu Value Added Tax Act, 2006, which contains a complete remedial framework for assessment disputes, including appeal, revision and rectification. In matters of tax recovery and assessment, the rule of alternative remedy operates with greater rigour, and the High Court ordinarily does not entertain writ proceedings when statutory remedies are available. The judgment applied the settled principle that a party must ordinarily exhaust the remedy provided by the statute before invoking writ jurisdiction, and found no sufficient ground to bypass that machinery.

Conclusion: The writ appeals were not maintainable on merits in view of the available statutory remedies, and the dismissal of the writ petitions was upheld.

Ratio Decidendi: Where a special tax statute provides an effective mechanism of appeal, revision or rectification, writ jurisdiction should ordinarily not be invoked to challenge assessment orders unless a recognised exception to the rule of alternative remedy is made out.

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