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Issues: Whether the petitioners were entitled to supply of the complete relied upon documents before the adjudicating authority proceeded with the matter, and whether the service of notice through electronic mode was valid.
Analysis: Rule 13(2) of the Adjudicating Authority (Procedure) Regulations, 2013 requires service of the noticee along with complete relied upon documents in a bound paper book, while Rule 13(3) permits service by electronic mail and Rule 13(11) treats communication through electronic mode as valid service. The petitioners had already participated by seeking inspection, requesting additional documents, and filing para-wise comments, but they continued to dispute whether the documents supplied constituted the complete relied upon documents. The Court held that it was for the adjudicating authority to determine whether the documents already furnished were the complete relied upon documents and, if not, to direct supply before further hearing. The Court also found no illegality in the recording of reasons to believe and noted the availability of proceedings before the adjudicating authority and the statutory appellate remedy.
Conclusion: The petitioners succeeded to the extent that the adjudicating authority was directed to first decide the question of complete supply of relied upon documents and, if further relied upon documents were found necessary, to ensure their supply before proceeding further. Electronic service of notice was treated as valid.
Final Conclusion: The writ petition was disposed of with directions securing adjudicatory fairness at the stage of consideration of the show cause notice and document supply.
Ratio Decidendi: Where a statute or regulatory scheme requires service of notice along with complete relied upon documents, the adjudicating authority must first determine whether the supplied materials are complete before proceeding to further hearing, and valid electronic service does not by itself cure any omission in supplying the required documents.