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Issues: Whether the show-cause notice issued by the Central Excise authority was liable to be quashed at the threshold on the grounds that it was issued with bias, amounted to a final adjudication, and called for interference under writ jurisdiction at the show-cause stage.
Analysis: Interference with a show-cause notice is justified only where the notice is shown to be without jurisdiction, manifestly biased, or a mere farce because the authority has already prejudged the issue. The notice in question was issued pursuant to earlier agreed terms and expressly left the classification and demand to be determined by the adjudicating authority after notice and hearing. Its language did not conclusively decide the controversy or demonstrate pre-determination. The Court therefore held that the petitioners had not made out a case for invoking writ jurisdiction against the notice at that stage.
Conclusion: The challenge to the show-cause notice failed; the notice was not quashed and no interference was warranted at the show-cause stage.
Ratio Decidendi: Writ jurisdiction should not be used to quash a show-cause notice unless the notice is shown to be without jurisdiction or vitiated by clear pre-judgment or bias on its face.