Access to seized documents in GST investigations affirmed, while judicial interference with investigation venue was declined.

Where seized documents are proposed to be relied upon in a GST notice or other proceeding, the person from whom they were taken must be given copies before further action is taken, and documents not so relied upon should be returned after the investigation stage. The Court also declined to interfere with the investigating authority's administrative choice of venue, holding that the selection of place and manner of investigation lies within investigative discretion and does not ordinarily warrant interference under Article 226. The writ petitions therefore succeeded only to the extent of access to relied-upon seized documents, while the request to transfer the investigation was rejected.

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Issues: (i) whether the petitioners were entitled to copies of seized documents relied upon in the ongoing investigation, and (ii) whether the investigation should be transferred from Ernakulam to Kollam.

Issue (i): whether the petitioners were entitled to copies of seized documents relied upon in the ongoing investigation

Analysis: The petitioners sought copies of documents seized from their premises during the GST investigation. The Court held that where the respondents propose to rely upon any seized document in a notice or other proceeding, the petitioners must be afforded copies of those documents before further action is taken. It was also directed that after the investigation stage, all seized documents not relied upon for further proceedings should be returned to the petitioners.

Conclusion: The issue was answered in favour of the petitioners, and the respondents were directed to furnish copies of relied-upon seized documents and to return the remaining seized documents after investigation.

Issue (ii): whether the investigation should be transferred from Ernakulam to Kollam

Analysis: The Court declined to interfere with the administrative choice of the investigating authority regarding the place and manner in which the investigation was to be conducted. It held that such matters fall within the leeway available to the respondents in investigative administration, and that interference under Article 226 was not warranted.

Conclusion: The issue was decided against the petitioners, and the request for transfer of the investigation to Kollam was rejected.

Final Conclusion: The writ petitions succeeded only to the extent of securing access to relied-upon seized documents, while the challenge to the venue of the investigation failed.

Ratio Decidendi: A person from whom documents are seized is entitled to copies of those documents when they are relied upon in subsequent proceedings, but the Court will not ordinarily interfere with the investigating authority's administrative choice of forum or manner of conducting the investigation.

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