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Issues: Whether, for a single pending appeal arising from a consolidated order passed on multiple show cause notices, one declaration in Form SVLDRS-1 was sufficient under Rule 3(2) of the Sabka Vishwas (Legacy Dispute Resolution) Rules, 2019, and whether rejection of the declaration on the ground that separate declarations were required for each notice was justified.
Analysis: Rule 3(2) requires a separate declaration for each "case", and the Explanation to the Rule treats a show cause notice or one or more appeals arising out of such notice as one case where the appeal is pending as on 30 June 2019. The notices in question had already been adjudicated by one consolidated order, the appellate authority had passed a combined order, and a single appeal was pending before the Tribunal. In that setting, the declaration related to one pending appeal and not to four separate pending cases. The Court also accepted that Section 13(2) of the General Clauses Act, 1897 supported reading the singular to include the plural where the statutory context so required. The rejection of the declaration on a purely technical ground was therefore unsustainable.
Conclusion: One declaration in Form SVLDRS-1 was sufficient for the single pending appeal, and rejection of the declaration for want of four separate declarations was not justified.
Final Conclusion: The rejection order was set aside and the matter was sent back for fresh decision on the declaration/application in accordance with law.
Ratio Decidendi: Where multiple show cause notices have merged into a consolidated adjudication and one appeal alone is pending, a single declaration under the beneficial settlement scheme is maintainable, and the singular expression in the scheme may be read to include the plural to avoid a hyper-technical defeat of the relief.
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