Parallel GST proceedings barred where the same cause of action exists; Haryana GST portion of FIR quashed and interim bail confirmed.

Parallel GST proceedings based on the same factual foundation were held impermissible under the GST regime, so the FIR was quashed to the extent it invoked the Haryana Goods and Services Tax Act, 2017, while the IPC offences were left to continue. The record reflected an admitted identity of cause of action between the earlier GST investigation and the Haryana FIR, engaging the bar against duplicate proceedings. Interim bail granted to certain petitioners was also made absolute because their role was stated to be limited and there was no report of misuse of the concession.

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Issues: (i) Whether the FIR could be quashed to the extent it proceeded under the Haryana Goods and Services Tax Act, 2017 on the ground that the same cause of action had already been initiated under the Central Goods and Services Tax Act, 2017 under the bar contained in section 6(2)(b) of the GST enactments. (ii) Whether the interim bail granted to certain petitioners in the connected criminal matters deserved to be confirmed as regular bail.

Issue (i): Whether the FIR could be quashed to the extent it proceeded under the Haryana Goods and Services Tax Act, 2017 on the ground that the same cause of action had already been initiated under the Central Goods and Services Tax Act, 2017 under the bar contained in section 6(2)(b) of the GST enactments.

Analysis: The record showed that the proceedings initiated by the Directorate General of GST Intelligence on the earlier date and the Haryana FIR were founded on the same set of facts. The Excise and Taxation Commissioner, Haryana, accepted that the Delhi case and the Haryana case were on the same factual foundation and that section 6 of the CGST/HGST regime applied. In view of the admitted identity of the cause of action, continuation of parallel proceedings under the State enactment was impermissible.

Conclusion: The FIR was quashed only to the extent it related to offences under the Haryana Goods and Services Tax Act, 2017, and the prosecution for the IPC offences was left to continue. This issue was decided in favour of the petitioners.

Issue (ii): Whether the interim bail granted to certain petitioners in the connected criminal matters deserved to be confirmed as regular bail.

Analysis: The petitioners had already been extended interim bail on the footing that their role was limited and that they had not misused the concession. The State did not dispute that, at least at that stage, the allegations against them were of the limited nature recorded earlier. There was no report of misuse of bail, and the Court found no reason to deny parity and continuation of the liberty already granted.

Conclusion: The interim bail orders were made absolute on the same terms and conditions. This issue was decided in favour of the petitioners.

Final Conclusion: The connected matters were disposed of in part by quashing the State GST component of the FIR and confirming bail in the matters where interim liberty had already been granted, while leaving the remaining criminal allegations and the separately adjourned petitions to proceed in accordance with law.

Ratio Decidendi: Where parallel GST proceedings are founded on the same cause of action, continuation of the later proceeding under the other GST enactment is impermissible; and interim bail may be confirmed where the accused has not misused the concession and the material shows only a limited role at the relevant stage.

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