Judicial review of film tax exemption recommendations is limited absent clear illegality, mala fides or concrete proof.

Entertainment tax exemption decisions based on a committee's film review recommendations are not ordinarily disturbed in judicial review absent clear illegality or proved mala fides. Although allegations of favouritism, nepotism and an improper committee constitution were raised, they were found too broad and unsupported by concrete evidence to justify quashing the Government Orders or upsetting the completed recommendations. The court also treated the passage of time as a relevant factor against interference, especially where the administrative exercise had long since been concluded. The requested writ relief was therefore declined.

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Issues: Whether the impugned Government Orders and the Committee's recommendations relating to entertainment tax exemption for films were liable to be quashed on the grounds of mala fides, discrimination, improper constitution of the Committee, and arbitrariness in the grant of exemption.

Analysis: The Court noted that the Committee constituted to view the films had made consistent recommendations and that the impugned administrative action had taken place years earlier. It held that expert recommendations are ordinarily not to be interfered with in judicial review unless clear illegality or mala fides is established. Although the Court expressed concern about allegations of favouritism, nepotism, and the manner of appointments, it found the allegations to be broad and unsupported by concrete proof sufficient to undo the completed exercise. The Court also observed that, because of the passage of time, interference was no longer desirable.

Conclusion: The prayer to quash the Government Orders and upset the Committee's recommendations was declined, and the writ petitions were not granted the substantive relief sought.

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