Public interest litigation limits: unverified tax-evasion allegations and roving enquiries will not justify judicial intervention.

A public interest writ seeking a mandamus for investigation into alleged tax evasion, undervaluation and foreign exchange loss is described as unsustainable where it rests only on unverified departmental communications. The text states that prior audit and departmental scrutiny had already examined the allegations and found no prima facie undervaluation, revenue loss or foreign exchange loss. It also notes that PIL jurisdiction should not be used for roving enquiries or vexatious, publicity-oriented litigation, and that the Court must be satisfied about the petitioner's bona fides and the seriousness of the material placed before it. On that basis, the relief is stated to have been declined.

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Issues: Whether the writ petition seeking a mandamus for investigation and action on allegations of tax evasion, undervaluation, and foreign exchange loss disclosed a bona fide public interest cause warranting judicial intervention.

Analysis: The petitioner's case rested entirely on communications and allegations made by a departmental officer, without any independent verification or supporting material showing prima facie illegality in the export pricing or tax treatment of the respondent company. The allegations had already been examined at multiple levels, including audit and departmental scrutiny, and those enquiries did not disclose undervaluation, revenue loss, or foreign exchange loss. In such circumstances, directing a fresh investigation would amount to a roving enquiry, which is impermissible in public interest litigation. The Court also applied the settled caution that PIL jurisdiction must not be used for vexatious, publicity-oriented, or mala fide litigation, and that the Court must be satisfied about the bona fides of the petitioner and the seriousness of the information placed before it.

Conclusion: The writ petition was not maintainable on the materials placed and the relief sought was declined; the petition was held to be vexatious and lacking bona fides.

Ratio Decidendi: A public interest petition seeking investigation cannot be entertained on the basis of unverified and repetitive allegations already found unsustainable by competent authorities; judicial intervention will be refused where the prayer would require a roving enquiry and the petition lacks bona fides.

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