GST demand based on data mismatch and alleged natural justice breach rejected; writ dismissed, petitioner directed to use statutory appeal remedy.

Alleged breach of natural justice in issuance of a GST demand notice based on mismatch was rejected on the ground that no exceptional or extraordinary circumstances justified bypassing the statutory appellate route; the court applied the doctrine of minimal judicial interference and found no substantiated prejudice, consequently dismissing the writ and granting liberty to pursue the prescribed statutory remedy. The operative effect is to reinforce that availability of an adequate alternative statutory appeal ordinarily bars relief by prerogative writs absent a compelling departure from normal appellate process.

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Issues: Whether the writ petition challenging the order dated 01.12.2025 passed under Section 74 of HGST/CGST/IGST Act, 2017 should be entertained on the ground of violation of principles of natural justice, or whether the petitioner must be relegated to the statutory remedy of appeal under Section 107.

Analysis: The Court examined the timeline of notices, adjournments sought, and absence of substantive response by the petitioner, noting that the petitioner did not respond to ASMT-10 nor to show cause notice DRC-01 and sought an adjournment only shortly before the impugned order. The Court applied established principles that writ jurisdiction under Article 226 is to be exercised sparingly where an efficacious statutory remedy exists, and intervention is justified only in exceptional and extraordinary circumstances. The Court found no such exceptional circumstances or substantiated breach of natural justice on the record that would warrant overriding the availability of the statutory appeal under Section 107.

Conclusion: Writ petition dismissed; petitioner relegated to statutory remedy of appeal under Section 107 and no interference is warranted on merits at this stage.

Ratio Decidendi: Where an efficacious alternative statutory remedy exists, courts will decline to exercise writ jurisdiction under Article 226 except in exceptional and extraordinary circumstances; mere procedural grievances or requests for adjournment do not displace the availability of the statutory appeal absent shown violation of natural justice.

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