Court denies reward claim, finds info not basis for investigation, upholds confidentiality of intelligence process.

The court dismissed the petition, ruling that the petitioner's claim for a reward was rightfully denied. It found that the petitioner's information did not form the basis of the investigation and that the department had acted independently. The court emphasized that the petitioner's entitlement to a reward did not align with the policy and guidelines, and there was a factual dispute regarding the source and usefulness of the information. It held that such matters could not be investigated in writ jurisdiction to maintain the confidentiality of the department's intelligence processes.

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Issues Involved:
1. Entitlement to Reward
2. Validity of Information Provided
3. Department’s Use of Information
4. Procedural Fairness and Natural Justice
5. Discretion of Reward Granting Authority

Issue-wise Detailed Analysis:

1. Entitlement to Reward:
The petitioner claimed entitlement to a reward under a scheme framed by the respondents for providing vital information about tax evasion. He argued that his information led to the investigation and the eventual recovery of Rs. 6 crores from M/s. ICC Worldwide Pvt. Ltd. The petitioner asserted that he had taken significant risks and spent his own money to gather and forward this information, expecting a reward as per the department’s policy.

2. Validity of Information Provided:
The petitioner detailed how he monitored the activities of e-commerce companies and identified M/s. ICC Worldwide Pvt. Ltd. as a major tax evader. He provided information about the misuse of customs duty concessions and the smuggling activities of the company. The petitioner communicated this information to Mr. P. K. Dash and other officials via WhatsApp and email, expecting it to be treated as DRI-I (information report) under the reward policy.

3. Department’s Use of Information:
The respondents, represented by the Directorate of Revenue Intelligence (DRI), argued that the investigation against M/s. ICC Worldwide Pvt. Ltd. was based on institutional information and intelligence gathered by the department’s own sources, not on the petitioner’s inputs. The DRI claimed that the petitioner’s information was vague and did not lead to the discovery of any new facts. They maintained that the department had already been investigating the company based on information received from other government agencies, including the Central Bureau of Investigation (CBI).

4. Procedural Fairness and Natural Justice:
The petitioner contended that the department’s refusal to grant him a reward was arbitrary and violated principles of natural justice. He argued that the impugned communication denying the reward was unreasoned and non-speaking. The petitioner also claimed that he was not given an opportunity to present his case before the deciding authority, despite his repeated requests for a hearing.

5. Discretion of Reward Granting Authority:
The court noted that the reward scheme is an ex gratia payment subject to the discretion of the competent authority. The guidelines specify that rewards are not a matter of right and are determined based on the specificity and accuracy of the information, the risk undertaken, and the extent of help rendered by the informer. The court emphasized that the department’s assessment of the petitioner’s claim, which found his information to be insufficient and already under investigation, was not liable to be interfered with in writ jurisdiction.

Conclusion:
The court dismissed the petition, finding that the petitioner’s claim for a reward was rightly negatived. It held that the petitioner’s information was not the basis for the investigation and that the department had acted on its own intelligence. The court also noted that the petitioner’s entitlement to a reward was not consistent with the policy or guidelines and that there was a clear factual dispute regarding the source and usefulness of the information provided. The court concluded that it could not probe such matters in writ jurisdiction, as it would require compromising the confidentiality of the department’s intelligence-gathering processes.

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