Writ jurisdiction and alternative remedy: disputed facts over prior GST notice were not suitable for writ review.

Where the validity of an impugned GST action turns on a disputed factual question, such as whether prior notice under Section 142(1)(a) was issued, the issue is ordinarily not fit for writ adjudication under Article 226. The presence of an efficacious statutory remedy further supports refusal to entertain the writ petition. The Court therefore found no error in declining writ jurisdiction on the ground of alternative remedy, and the writ appeal was dismissed.

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Issues: Whether the writ appeal was maintainable despite the availability of an alternative statutory remedy, and whether the alleged absence of prior notice under Section 142(1)(a) of the Central Goods and Services Tax Act, 2017 could be examined in writ jurisdiction.

Analysis: The challenge rested on the contention that no statutory notice had been issued before the show cause notice and that the impugned order was therefore null and void. The Court held that the existence or non-existence of such prior notice was itself a factual dispute. In view of the settled limits on the exercise of jurisdiction under Article 226 of the Constitution of India, such disputed factual questions were not fit for adjudication in writ proceedings, particularly when an efficacious statutory remedy was available.

Conclusion: The Court found no error in the refusal to entertain the writ petition on the ground of alternative remedy and held that the writ appeal was liable to be dismissed.

Ratio Decidendi: Where the validity of an impugned action turns on a disputed factual question and an effective statutory remedy exists, writ jurisdiction will ordinarily not be invoked.

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