Writ jurisdiction declined where product classification depended on disputed technical facts and an effective statutory remedy was available.

Where classification of an imported product depended on conflicting laboratory reports and expert evidence, the Bombay HC declined to exercise writ jurisdiction under Article 226. The Court held that questions whether the goods were proprietary food or carbonated water could not be conclusively decided in writ proceedings because they involved disputed technical facts. It also noted that an efficacious statutory remedy was available, and that the petitioners could seek appropriate relief, including release of goods, before the competent criminal court in the pending proceedings. The writ petition was therefore not maintainable on the facts presented.

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Issues: Whether the writ petition should be entertained under Article 226 when an alternate and equally efficacious remedy was available and the controversy turned on disputed questions of fact requiring expert determination.

Analysis: The reliefs sought required the Court to classify the imported product as proprietary food rather than carbonated water and to direct release of seized goods. The record showed conflicting laboratory reports and pending criminal proceedings arising from the seizure. The determination of the product's correct classification and the correctness of the analysis reports depended on technical evidence and expert opinion, which could not be conclusively resolved in writ proceedings. The petitioners were also free to pursue statutory remedies and to seek appropriate relief, including release of goods, before the competent criminal court in the pending proceedings.

Conclusion: The writ petition was not maintainable in the facts of the case and was liable to be dismissed in view of the alternate remedy and the disputed factual issues.

Ratio Decidendi: Where the dispute turns on technical and factual questions requiring evidence and expert opinion, and an efficacious statutory remedy is available, the Court should decline to exercise writ jurisdiction under Article 226.

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