Natural Justice breached: adjudication proceeded in undue haste and order quashed with remand for fresh hearing.

Challenge concerned whether a time bound adjudication under the GST framework violated principles of natural justice by proceeding despite notice of pending judicial proceedings. Court applied principles requiring fair, non arbitrary administrative action and an opportunity of personal hearing; actions taken in undue haste or as a colourable exercise of power offend equality and the rule of law. Outcome: the impugned adjudication was quashed and the matter remitted for fresh consideration after the petitioner is given an opportunity to file explanations and a personal hearing within prescribed short timelines.

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Issues: Whether the Order-in-Original dated 19.12.2025 passed under Section 74 of the GST Act (Central and Odisha) is vitiated for violation of principles of natural justice and undue haste in adjudication, and whether the order should be quashed and remitted for fresh adjudication with opportunity of hearing.

Analysis: The Court examined the sequence of events: an original Demand-cum-Show Cause Notice dated 26.06.2025, an application for rectification under Section 161, the Court's direction dated 25.09.2025 to consider the rectification application and proceed in connection with the 26.06.2025 notice, issuance of fresh notices for FY 2018-19 to 2022-23, filing of W.P.(C) No.36758 of 2025, intimation to the authority on 18.12.2025 about the pending writ, and the authority's passing of the adjudication order on 19.12.2025. The adjudication record shows the authority proceeded on a time-bound basis citing the statutory deadline without awaiting the outcome of the pending writ and after being informed of the challenge. The Court applied established principles that administrative action must be fair, not arbitrary, and must afford an opportunity of hearing; actions taken in undue haste or that display a colourable exercise of power offend Article 14 and the rule of law. The Court found on the record that the authority finalized the demand notwithstanding the pendency of related judicial proceedings and did so in a manner that caused prejudice to the petitioner by failing to afford a proper hearing and by acting with undue haste.

Conclusion: The Order-in-Original dated 19.12.2025 is quashed. The petitioner is directed to file explanation/reply/objection within seven days and the authority shall consider the Demand-cum-Show Cause Notice dated 17.11.2025 read with summary dated 25.11.2025 and pass a fresh order within fifteen days after affording an opportunity of personal hearing. The writ petitions are allowed in favour of the petitioner.

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