Gross delay and laches barred a delayed writ challenge; later detention notice was only a consequential recovery step.

A writ petition challenging an assessment and demand was held barred by gross delay and laches because the petitioners had already pursued the statutory appellate chain and filed the writ months after the final departmental decision. The later detention notice was treated only as a consequential recovery step for an unchallenged liability, not as a fresh independent cause of action. Earlier correspondence had already warned that coercive action under section 39 could follow default, so the delayed attempt to recast the challenge as a statutory appeal was rejected.

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Issues: Whether the petition was liable to be entertained in view of gross delay and laches, and whether the later detention notice or enforcement step furnished a fresh cause to challenge the assessment and demand.

Analysis: The petitioners had already pursued the assessment through the statutory appellate chain, and the final departmental decision was made months before the writ petition was filed. The later notice threatening detention of goods was treated as a consequential step taken to recover an unchallenged liability, not as a new independent grievance that could restart limitation or justify a delayed writ. The earlier correspondence had already put the petitioners on notice that coercive action under section 39 could follow default, and the attempt to treat a petition seeking sympathy rather than a challenge to the earlier orders as a statutory appeal was rejected.

Conclusion: The petition was barred by gross delay and laches and could not be entertained.

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