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[Cites 7, Cited by 0]

Madras High Court

Padmavathi Hospitality And Facilities vs The Tamil Nadu Medical Service ... on 9 September, 2020

Author: Senthilkumar Ramamoorthy

Bench: A.P.Sahi, Senthilkumar Ramamoorthy

                                  IN THE HIGH COURT OF JUDICATURE AT MADRAS

                                                DATED: 09.09.2020

                                                     CORAM :

                                     THE HON'BLE MR.A.P.SAHI, CHIEF JUSTICE
                                                       AND
                               THE HON'BLE MR.JUSTICE SENTHILKUMAR RAMAMOORTHY

                                               W.A.No.711 of 2020


                      Padmavathi Hospitality and Facilities
                       Management Service
                      rep. by its Authorized Representative
                      J.Anjananandan,
                      No.2-B, 2nd Floor J.V.L.Towers
                      New No.51 Old No.117
                      Nelson Manickam Road, Aminjikarai,
                      Chennai – 600 029.                               .... Appellant

                                                          vs

                      1   The Tamil Nadu Medical Service Corporation
                          (A Government of Tamil Nadu undertaking)
                          No.417 Pantheon Road Egmore
                          Chennai - 600 008.

                      2   The Director of Medical Education
                          Directorate of Medical Education
                          Kilpauk, Chennai - 10.

                      3   The Assistant Commissioner GST
                          Chennai North Commissionerate
                          No.2054, I Block, Newry Towers
                          12th Main Road, 2nd Avenue
                          Anna Nagar, Chennai - 600 040.


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                      4   Krystal Integrated Services Pvt. Ltd.
                          No.15, Krystal House, Dr.Mankikar Road
                          Sion East, Mumbai - 400 022.

                      5   The Assistant Commissioner (CT)
                          State GST, Koyambedu GST Circle
                          CMDA Administration Building
                          2nd Floor, Koyambedu
                          Chennai - 600 107.

                      6   Tamil Nadu Advance Ruling Authority
                          PAPJM Buildings, II Floor
                          No.1, Greams road
                          Chennai.                                    .... Respondents


                      PRAYER: Appeal under Clause 15 of the Letters Patent to set aside the

                      order dated 28.2.2020 passed by the learned Single Judge in

                      W.P.No.24412 of 2019



                                For Appellant           : Mr.Nithyaesh Natraj

                                For 1st respondent      : Mr.Shivakumar

                                For 2nd respondent      : Mr.Karthikeyi Balan

                                For respondents 3 and 5 : Mr.Mohammed Saffiq
                                                          Spl. Government Pleader

                                For 4th respondent      : Mr.P.Vinod Kumar




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                                                      JUDGMENT
                                        (Delivered by The Hon'ble Chief Justice)




                               This appeal is limited for a relief against the observations and

                      directions contained in paragraphs (41) and (42) of the impugned

                      judgment dated 28.2.2020, in a challenge raised by the appellant

                      in W.P.No.24412 of 2019 relating to a dispute regarding acceptance

                      of a bid and award of a contract pursuant to the tender notice dated

                      19.2.2019.



                               2. Another writ petition, being W.P.No.27267 of 2019, was

                      filed by a separate petitioner, wherein the said petitioner claimed

                      the bid for itself, and for rejecting the bid of the appellant herein as

                      well as the successful bidder, M/s.Krystal Integrated Services

                      Private Limited, fourth respondent herein.       Both the writ petitions

                      were taken up together and have been dismissed. While dismissing

                      the writ petitions, the learned Single Judge has made the following

                      observations in paragraphs (40) to (42), which are reproduced

                      herein under:



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                                “40. The reasons and the law laid down by the Hon'ble
                                Supreme Court are binding. I hold that both the Writ
                                Petitioners have embarked on a speculative journey to
                                deliberately frustrate further progress in the tender process.
                                Both the Writ Petitions have to suffer an order of dismissal
                                and accordingly they are dismissed.


                                41. It must also be stated that the learned counsel for the
                                Writ petitioner in W.P.No.24412 of 2019, made the following
                                endorsement in the Writ Petition on the last day when the
                                writ petitions were reserved for orders:
                                   'Petitioner may be permitted to withdraw with liberty'
                                This Court expresses its deep displeasure over such an
                                endorsement     made    by    the   learned   counsel   for   the
                                petitioner. It exhibits lack of professional ethics. It is very
                                specifically ordered that no liberty of any kind is granted for
                                the Writ Petitioner in W.P.No.24412 of 2019.


                                42. Both the Writ Petitions are dismissed. Each of the Writ
                                Petitioners are directed to pay costs of Rs.5,00,000/-
                                (Rupees Five Lakhs only) to the Chief Justice Relief Fund,
                                High   Court   of   Madras.   Consequently,    connected      Writ
                                Miscellaneous Petitions are closed.”




                               3. We are not concerned with the observations made or the

                      relief prayed for by the other writ petitioner in W.P.No.27267 of

                      2019 and the present appeal is confined to the limited relief as

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                      prayed for by the appellant in the appeal arising out W.P.No.24412

                      of 2019 only.



                               4. Having entertained the appeal, we had passed the following

                      order on 27.7.2020, while issuing notice:

                                “We      have   heard   learned    counsel   for   the    petitioner
                                Mr.Shivakumar, learned counsel appearing for the first
                                respondent; Mr.P. Vinod Kumar,          learned counsel for the
                                fourth     respondent    and      Mr.V.Jayaprakash       Narayanan,
                                learned State Government Pleader for the State and its
                                authorities.


                                2.       Issue Notice to the unserved respondents returnable
                                at an early date.


                                3.       Learned counsel may also take private notice to the
                                unserved respondents and a copy of the papers be
                                circulated to all the learned counsels.


                                4.       Learned counsel for the appellant has urged that this
                                appeal is limited in its scope questioning the correctness of
                                the observations, directions and imposition of cost as
                                contained in paragraph Nos.41 and 42 of the impugned
                                judgment dated 28.02.2020. Learned counsel submits that
                                the petitioner had instructed the counsel to withdraw the
                                writ petition with liberty, as an application before the


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                                Advance Ruling Authority was pending which was also one
                                of the alternative remedies available in respect of the
                                dispute that has been raised in the writ petition.


                                5.    It is the contention of the learned counsel that on
                                06.02.2020, he was granted permission to make the
                                endorsement of withdrawal on the record, which was duly
                                made, in the hope that the writ petition filed insofar as the
                                present appellant    is concerned, had been permitted to
                                withdraw with liberty to approach the Advance Ruling
                                Authority, but, when the impugned judgment was delivered
                                on 28.02.2020,      the appellant's counsel was taken by
                                surprise with the observations made and cost imposed on
                                the appellant.


                                6.    Learned counsel has clarified that the other writ
                                petitioner had been contesting his writ petition and there
                                was no endorsement by the said writ petitioner for
                                withdrawing the case. He also points out that        this matter
                                had been heard at length before another learned Single
                                Judge,   where   written   arguments    had   been     filed   on
                                04.10.2019 and inspite of the matter having been heard and
                                judgment reserved by the learned Single Judge, the same
                                was not pronounced, as a result thereof, the matter came to
                                be heard by another learned Single Judge, who has now
                                dismissed the writ petition with the said observations.


                                7. The contention is that there was no attempt on the part



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                                of    the   appellant   to    put    the   Court    to   any   form   of
                                inconvenience or seek adjournment or any unnecessary
                                indulgence, and he was simply pursuing his legitimate and
                                bona fide right to seek a judicial review from this Court in a
                                contractual    matter    to    the    extent   it   may    have   been
                                permissible.


                                8.      In this background, once the petitioner had sought
                                withdrawal and had endorsed it, then, the dismissal of the
                                writ petition and imposition of cost without putting the
                                appellant's counsel to notice on this ground, is not justified,
                                more so, in the back ground of the litigation as indicated
                                above.


                                9.      The Respondents may give their limited response on
                                this issue, which has been raised in this appeal.


                                10.     Having considered the submissions raised by the
                                learned counsel for the respondents as well, prima facie we
                                find that a case for grant of interim relief has been made
                                out.


                                11.     Accordingly, until further orders of this Court, we stay
                                the operation of paragraph Nos.41 and 42 of the impugned
                                judgment dated 28.02.2020.


                                List the matter on 07.09.2020.”




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                               5. The appellant had also taken a plea in his writ petition that

                      the appellant had made an application for advance ruling on the

                      applicability of Goods and Service Tax in respect of the information

                      required for the tender before the Advance Ruling Authority. It is in

                      this context that the relief for setting aside the tender proceedings

                      was prayed for in the writ petition.



                               6. Noticing the aforesaid fact, the learned Single Judge while

                      hearing the writ petition giving rise to this appeal, on 14.11.2019,

                      had passed the following order:

                                “Heard Mr. AR.L. Sundaresan, Learned Senior Counsel
                                appearing for the Petitioner, Mr. V.M. Shivakumar appearing
                                for the First Respondent, Mr. Vijay Narayan, Learned
                                Advocate General assisted by Mr. R. Venkatesh, Learned
                                Government        Advocate   appearing     for   the   Second
                                Respondent,   Mr.    M.   Santhanaraman,    Learned    Counsel
                                appearing for the Third Respondent, Mr. D. Ravichander,
                                Learned Counsel appearing for the Fourth Respondent and
                                Mr. M. Hariharan, Learned Additional Government Pleader
                                appearing   for   the   Fifth Respondent   and perused     the
                                materials placed on record, apart from the pleadings of the
                                parties.


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                                2. Notice to the Sixth Respondent returnable by 22.11.2019.
                                Private notice is also permitted.


                                3. Learned Senior Counsel appearing for the Petitioner
                                submits that the Petitioner had made an application for
                                advance ruling on the applicability of Goods and Service Tax
                                in respect of the tender, which forms the subject of this Writ
                                Petition, before the Sixth Respondent, and in view of the
                                first proviso to Section 98(2) of the Central Goods and
                                Services Tax Act, 2017, seeks a clarification from this Court
                                for enabling the Sixth Respondent to pass orders in that
                                application.


                                4. Having regard to the facts involved in this case, and in
                                particular, the Counter Affidavit dated 12.11.2019 filed by
                                the Third Respondent, the pendency of this Writ Petition
                                shall not preclude the Sixth Respondent from deciding the
                                aforesaid application for advance ruling said to have been
                                made by the Petitioner.


                                5. Learned Counsel for the parties seek time to make
                                further submissions in the Writ Petition. Post the matter
                                along with W.P. No. 27267 of 2019 on 22.11.2019 at the
                                end of the list.”




                               7. The contention of the learned counsel for the appellant is


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                      that it is for this reason that the appellant made a request before

                      the learned Single Judge to allow the appellant to withdraw his writ

                      petition, for which an endorsement was made so that he may have

                      the liberty to pursue the appeal before the Advance Ruling

                      Authority.



                            8. The contention of the learned counsel for the appellant is

                      that the endorsement made for withdrawal of the writ petition was

                      unequivocal, as the appellant did not wish to contest the writ

                      petition since he was pursuing his application before the Advance

                      Ruling Authority, the Court ought to have simply dismissed the writ

                      petition and there was no justification for having imposed costs.



                            9. It is submitted that since the Advance Ruling Authority had

                      failed to decide the application in spite of the said observation made

                      by the learned Single Judge on 14.11.2019 during the pendency of

                      the writ petition, there was no option to the appellant except to

                      pursue his cause and make a request to that effect.




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                            10. In spite of the endorsement having been made, the Court

                      instead of passing an order of dismissing the writ petition permitting

                      the appellant to withdraw the same, has proceeded to express its

                      anguish on account of the pendency of the writ petition terming it

                      as a speculative journey for frustrating the tender process. Learned

                      counsel submits that the aforesaid observation of the learned Single

                      Judge in the background aforesaid, when the appellant himself has

                      volunteered to withdraw his writ petition, is not justified and the

                      Court ought not to have proceeded to decide the matter on merits,

                      nonetheless the appellant is only contesting the observations made

                      with regard to the right of withdrawal and the imposition of costs in

                      the present appeal.



                            11. Learned counsel for the parties have been heard and

                      Mr.Shivakumar, learned counsel for the first respondent submits

                      that since the appeal is limited only to these aspects and is confined

                      to the writ petition of the appellant, the Court may pass appropriate

                      orders.




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                            12. Mr.Karthikeyi Balan and Mr.Mohammed Saffiq, learned

                      counsel have been heard on behalf of the State, and Mr.P.Vinod

                      Kumar, learned counsel for the fourth respondent contends that it

                      was on account of the conduct of the appellant that the Court

                      proceeded to refuse withdrawal as well any liberty of any kind and

                      rightly imposed the cost, as a frivolous litigation was being pursued

                      by the appellant.



                            13. The aforesaid dispute has to be viewed in the light of the

                      principles of Order XXIII Rule 1 of the Civil Procedure Code. At the

                      outset, we may clarify that such principles relating to withdrawal

                      are applicable to writ petitions as well on the ground of public

                      policy, as held by the Apex Court in the case of Sarguja Transport

                      Service v. State Transport Appellate Tribunal, M.P., Gwalior and

                      others, (1987) 1 SCC 5, in paragraph (9), which is extracted herein

                      under:



                                “9. The point for consideration is whether a petitioner after
                                withdrawing a writ petition filed by him in the High Court
                                under Article 226 of the Constitution of India without the
                                permission to institute a fresh petition can file a fresh writ
                                petition in the High Court under that article. On this point


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                                the decision in Daryao v. State of U.P. [AIR 1961 SC 1457 :
                                (1962) 1 SCR 574] is of no assistance. But we are of the
                                view that the principle underlying Rule 1 of Order XXIII of
                                the Code should be extended in the interests of
                                administration of justice to cases of withdrawal of writ
                                petition also, not on the ground of res judicata but on the
                                ground of public policy as explained above. It would also
                                discourage the litigant from indulging in bench-hunting
                                tactics. In any event there is no justifiable reason in such a
                                case to permit a petitioner to invoke the extraordinary
                                jurisdiction of the High Court under Article 226 of the
                                Constitution once again. While the withdrawal of a writ
                                petition filed in a High Court without permission to file a
                                fresh writ petition may not bar other remedies like a suit or
                                a petition under Article 32 of the Constitution of India since
                                such withdrawal does not amount to res judicata, the
                                remedy under Article 226 of the Constitution of India should
                                be deemed to have been abandoned by the petitioner in
                                respect of the cause of action relied on in the writ petition
                                when he withdraws it without such permission. In the
                                instant case the High Court was right in holding that a fresh
                                writ petition was not maintainable before it in respect of the
                                same subject-matter since the earlier writ petition had been
                                withdrawn without permission to file a fresh petition. We,
                                however, make it clear that whatever we have stated in this
                                order may not be considered as being applicable to a writ
                                petition involving the personal liberty of an individual in
                                which the petitioner prays for the issue of a writ in the
                                nature of habeas corpus or seeks to enforce the
                                fundamental rignt guaranteed under Article 21 of the
                                Constitution since such a case stands on a different footing
                                altogether. We, however leave this question open.”




                      The aforesaid view in Sarguja Transport Service (supra) has been

                      reiterated in the case of Upadhyay & Co. v. State of U.P. and

                      others, (1999) 1 SCC 81. Another shade of the said issue has been

                      considered in the case of           Kandapazha Nadar and others v.

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                      Chitraganiammal and others, (2007) 7 SCC 65.             Further, the

                      limitation on the right of a defendant to object to a withdrawal has

                      been discussed in the case of Anil Kumar Singh v. Vijay Pal Singh

                      and others, (2018) 12 SCC 584.




                            14. We may further point out that it is subject to the

                      conditions as enunciated in the case of Radha Krishna v. State of

                      Rajasthan, AIR 1977 Raj 131, and subject to the powers of the

                      Court circumscribed to the extent as contained in Sub-Rule (4) of

                      Order XXIII Rule 1 of the Civil Procedure Code.



                            15. There are certain exceptions to this Rule which should also

                      be taken into consideration, namely, that the petition filed is a bona

                      fide attempt and not a mala fide attempt to consume the time of

                      the Court by way of forum shopping.            While explaining the

                      judgment in the case of Sarguja Transport Service (supra), the

                      Apex Court in the case of Sarva Shramik Sanghatana (KV) v. State

                      of Maharashtra, (2008) 1 SCC 494, in paragraphs (12) to (18),

                      held as under:



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                                “12. We have carefully examined the decision of Sarguja
                                Transport Service case [(1987) 1 SCC 5 : 1987 SCC (Cri) 19
                                : AIR 1987 SC 88] . In the said decision it is mentioned in
                                para 8 as follows: (SCC p. 11)
                                    '8. … It is common knowledge that very often after
                                    a writ petition is heard for some time when the
                                    petitioner or his counsel finds that the court is not
                                    likely to pass an order admitting the petition,
                                    request is made by the petitioner or by his counsel
                                    to permit the petitioner to withdraw the writ
                                    petition without seeking permission to institute a
                                    fresh writ petition. A court which is unwilling to
                                    admit the petition would not ordinarily grant liberty
                                    to file a fresh petition while it may just agree to
                                    permit the withdrawal of the petition.'
                                In para 9 of the said decision, it is also mentioned as
                                follows: (SCC p. 12)
                                    '9. … But we are of the view that the principle
                                    underlying Rule 1 of Order 23 of the Code should
                                    be extended in the interests of administration of
                                    justice to cases of withdrawal of writ petition also,
                                    not on the ground of res judicata but on the
                                    ground of public policy as explained above. It
                                    would also discourage the litigant from indulging in
                                    Bench-hunting tactics.'
                                                                    (emphasis supplied)




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                                We are of the opinion that the decision in Sarguja Transport
                                case [(1987) 1 SCC 5 : 1987 SCC (Cri) 19 : AIR 1987 SC
                                88] has to be understood in the light of the observations in
                                paras 8 and 9 therein, which have been quoted above. The
                                said decision was given on the basis of public policy that, if
                                while hearing the first writ petition the Bench is inclined to
                                dismiss it, and the learned counsel withdraws the petition so
                                that he could file a second writ petition before what he
                                regards as a more suitable or convenient Bench, then if he
                                withdraws it he should not be allowed to file a second writ
                                petition unless liberty is given to do so. In other words,
                                Bench-hunting should not be permitted.


                                13. It often happens that during the hearing of a petition
                                the court makes oral observations indicating that it is
                                inclined to dismiss the petition. At this stage the counsel
                                may seek withdrawal of his petition without getting a verdict
                                on the merits, with the intention of filing a fresh petition
                                before a more convenient Bench. It was this malpractice
                                which was sought to be discouraged by the decision in
                                Sarguja Transport case [(1987) 1 SCC 5 : 1987 SCC (Cri)
                                19 : AIR 1987 SC 88] .


                                14. On the subject of precedents Lord Halsbury, L.C., said in
                                Quinn v. Leathem [1901 AC 495 : (1900-1903) All ER Rep 1
                                (HL)] : (All ER p. 7 G-I)
                                    “Before discussing Allen v. Flood [1898 AC 1 :
                                    (1895-1899) All ER Rep 52 (HL)] and what was



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                                    decided therein, there are two observations of a
                                    general character which I wish to make; and one is
                                    to repeat what I have very often said before—that
                                    every judgment must be read as applicable to the
                                    particular facts proved or assumed to be proved,
                                    since the generality of the expressions which may
                                    be found there are not intended to be expositions
                                    of the whole law, but are governed and qualified by
                                    the particular facts of the case in which such
                                    expressions are to be found. The other is that a
                                    case is only an authority for what it actually
                                    decides. I entirely deny that it can be quoted for a
                                    proposition that may seem to follow logically from
                                    it. Such a mode of reasoning assumes that the law
                                    is necessarily a logical code, whereas every lawyer
                                    must acknowledge that the law is not always
                                    logical at all.”
                                                                   (emphasis supplied)
                                We entirely agree with the above observations.


                                15. In Ambica Quarry Works v. State of Gujarat [(1987) 1
                                SCC 213] (vide SCC p. 221, para 18) this Court observed:
                                    '18. The ratio of any decision must be understood
                                    in the background of the facts of that case. It has
                                    been said long time ago that a case is only an
                                    authority for what it actually decides, and not what
                                    logically follows from it.'




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                                16. In Bhavnagar University v. Palitana Sugar Mill (P) Ltd.
                                [(2003) 2 SCC 111] (vide SCC p. 130, para 59) this Court
                                observed:
                                    '59. … It is also well settled that a little difference
                                    in facts or additional facts may make a lot of
                                    difference in the precedential value of a decision.'
                                                                     (emphasis supplied)


                                17. As held in Bharat Petroleum Corpn. Ltd. v. N.R.
                                Vairamani [(2004) 8 SCC 579 : AIR 2004 SC 4778] a
                                decision cannot be relied on without disclosing the factual
                                situation. In the same judgment this Court also observed:
                                (SCC pp. 584-85, paras 9-12)
                                    '9. Courts should not place reliance on decisions
                                    without discussing as to how the factual situation
                                    fits in with the fact situation of the decision on
                                    which reliance is placed. Observations of courts are
                                    neither to be read as Euclid's theorems nor as
                                    provisions of a statute and that too taken out of
                                    their context. These observations must be read in
                                    the context in which they appear to have been
                                    stated.   Judgments    of   courts   are   not   to   be
                                    construed as statutes. To interpret words, phrases
                                    and provisions of a statute, it may become
                                    necessary for judges to embark into lengthy
                                    discussions but the discussion is meant to explain
                                    and not to define. Judges interpret statutes, they
                                    do not interpret judgments. They interpret words



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                                of statutes; their words are not to be interpreted
                                as statutes. In London Graving Dock Co. Ltd. v.
                                Horton [1951 AC 737 : (1951) 2 All ER 1 (HL)] (AC
                                at p. 761), Lord MacDermott observed: (All ER p.
                                14 C-D)
                                  ‘The matter cannot, of course, be settled
                                  merely by treating the ipsissima verba of
                                  Willes, J. as though they were part of an Act
                                  of   Parliament   and applying     the   rules   of
                                  interpretation appropriate thereto. This is not
                                  to detract from the great weight to be given
                                  to the language actually used by that most
                                  distinguished Judge, …’


                                10. In Home Office v. Dorset Yacht Co. Ltd. [1970
                                AC 1004 : (1970) 2 WLR 1140 : (1970) 2 All ER
                                294 (HL)] Lord Reid said,
                                  ‘Lord Atkin's speech … is not to be treated as
                                  if it were a statutory definition. It will require
                                  qualification in new circumstances.’ (All ER p.
                                  297g)
                                Megarry, J. in Shepherd Homes Ltd. v. Sandham
                                (No.2) [(1971) 1 WLR 1062 : (1971) 2 All ER
                                1267] , observed: (All ER p. 1274d)
                                  ‘One must not, of course, construe even a
                                  reserved judgment of even Russell, L.J. as if it
                                  were an Act of Parliament;’




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                                And, in British Railways Board v. Herrington [1972
                                AC 877 : (1972) 2 WLR 537 : (1972) 1 All ER 749
                                (HL)] Lord Morris said: (All ER p. 761c)
                                  ‘There is always peril in treating the words of
                                  a speech or a judgment as though they were
                                  words in a legislative enactment, and it is to
                                  be remembered that judicial utterances are
                                  made in the setting of the facts of a particular
                                  case.’
                                11. Circumstantial flexibility, one additional or
                                different fact may make a world of difference
                                between conclusions in two cases. Disposal of
                                cases by blindly placing reliance on a decision is
                                not proper.
                                12. The following words of Hidayatullah, J. in the
                                matter of applying precedents have become locus
                                classicus: (Abdul Kayoom v. CIT [AIR 1962 SC
                                680] , AIR p. 688, para 19)
                                  ‘19. … Each case depends on its own facts and
                                  a close similarity between one case and
                                  another is not enough because even a single
                                  significant detail may alter the entire aspect,
                                  in deciding such cases, one should avoid the
                                  temptation to decide cases (as said by
                                  Cardozo) by matching the colour of one case
                                  against the colour of another. To decide
                                  therefore, on which side of the line a case
                                  falls, the broad resemblance to another case
                                  is not at all decisive.’
                                  ...
                                  ‘Precedent should be followed only so far as it
                                  marks the path of justice, but you must cut
                                  the dead wood and trim off the side branches


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                                      else you will find yourself lost in thickets and
                                      branches. My plea is to keep the path to
                                      justice clear of obstructions which could
                                      impede it.’ ”              (emphasis supplied)

                                18. We have referred to the aforesaid decisions and the
                                principles laid down therein, because often decisions are
                                cited for a proposition without reading the entire decision
                                and the reasoning contained therein. In our opinion, the
                                decision of this Court in Sarguja Transport case [(1987) 1
                                SCC 5 : 1987 SCC (Cri) 19 : AIR 1987 SC 88] cannot be
                                treated as a Euclid's formula.



                            16. In the said decision, the Court held that the application for

                      withdrawal of the first writ petition had been made bona fide, as the

                      company was trying to bring about an amicable settlement.               The

                      assumption of any forum shopping does not arise in this case, as the

                      pursuit of an application before the Advance Ruling Authority is a

                      separate remedy, which may or may not have a bearing on the claim

                      of the appellant in the present proceedings, but the writ petition was

                      filed with regard to an award of tender, the forum of which was before

                      the learned Single Judge. This is not a case where the appellant had

                      withdrawn any earlier claim with regard to the tender process to

                      institute a fresh proceeding. We may further point out that it appears

                      that the reason for approaching the Advance Ruling Authority might

                      have been in order to clarify the status of applicability of Goods and


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                      Service Tax, as the appellant appears to have quoted rates by adding

                      Goods and Service Tax, whereas the fourth respondent had succeeded

                      in offering a lesser rate without adding the component of Goods and

                      Service Tax. This, in our opinion, was a bona fide pursuit on behalf of

                      the appellant.



                            17. The law relating to withdrawal of a claim in the light of the

                      word “abandon” used in Order XXIII of the Civil Procedure Code came

                      to be considered by a learned Single Judge of the Allahabad High Court

                      in the case of Bhajan Lal and others v. Rajmala, 2013 (2) ALJ

                      476, where in paragraphs (23), (24), (30) and (31), the following

                      observations have been made:

                                “23. This provision was amended with the word “abandon”
                                appearing in the Section which was previously a little
                                different from the present context. To abandon means to
                                relinquish or give up one's claim. It is a sort of renunciation
                                and unless taken to be otherwise, a voluntary resignation or
                                disowning of a claim. It is at times in the interest of another
                                and it seeks to repudiate one's rights. A person casts off his
                                vow to continue doing something and is a formal declaration
                                thereof. The person abandoning a claim is voluntarily
                                surrendering or sacrificing his claim. It is a disclaimer or
                                forsaking of a right. The action taken is sought to be



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                                retracted from and is, therefore, an absolute unconditional
                                withdrawal of one's right to pursue any further claim.


                                24. The provision of Order XXIII is, however, hedged with
                                limitations on this right of absolute withdrawal even where it
                                is unilateral and voluntary. The Court retains the powers of
                                imposing costs on terms & conditions even where the
                                withdrawal is unconditional. The other side of the coin is
                                that there can be cases where such abandonment is a result
                                of threat, coercion, fraud and misrepresentation. In short, it
                                is not voluntary or unilateral and, therefore, it cannot be
                                said to be an absolute withdrawal. There can be a
                                contingency where such expression of withdrawal can be
                                alleged to be not in a sound state of mind or even under a
                                mistaken belief or wrong advice. It is in such contingencies
                                that the inherent power of the Court under Section 151, CPC
                                has to be adverted to in order to rectify any mischief or
                                fraud or even correction of legally permissible mistakes.
                                Thus, the right of a litigant may be absolute for withdrawing
                                from a litigation but it is hedged with the aforesaid limitation
                                and, therefore, can be said to be subject to any orders
                                passed or adjudication before the withdrawal is treated to
                                be absolute. The intention, therefore, expressed to withdraw
                                from a Suit may require me passing of an order of the Court
                                before finality is attached to the same.
                                .....
                                30. The contention raised that Order 21, Rule 89(2) has
                                similar wordings and the order of the Court is not



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                                necessary, is not attracted, as the ingredients of Order
                                XXIII are entirely different as discussed hereinabove. A
                                litigant can surrender his right to contest a matter which is
                                the essence of Order XXIII. The right to withdraw such an
                                intention of surrender or revoke the same which can arise in
                                the circumstances as discussed hereinabove is a different
                                issue. These ingredients, therefore, in relation to the entire
                                disclaimer of the claim is not comparable with the provisions
                                of Order 21, Rule 89(2) in a matter arising out of execution.


                                31. There is yet another aspect which requires consideration
                                namely the consequences of such withdrawal which are
                                unilateral and voluntary. A litigant is precluded for all times
                                to come from raising any similar issue or claiming any
                                similar right. The consequences are, therefore, so absolute
                                that before any opinion is expressed thereon, the legal right
                                to waive a claim has to be assessed. It is true that a litigant
                                has a right and an unqualified right to withdraw from a
                                litigation but it is subject to certain conditions. The right to
                                contest or seek a judicial remedy partakes the nature of the
                                basic structure of the Constitution. It is controlled by law
                                made by the Parliament and the right to seek a judicial
                                remedy, therefore, cannot be denied to a litigant. Similarly,
                                the remedy already sought can be abandoned which is also
                                permitted by law. In my opinion, before an order is passed
                                by a Court formally terminating the litigation, this right to
                                revoke a withdrawal can also be exercised and to this
                                extent, the power of the Court is preserved in order to do



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                                complete justice between the parties. The reason is that a
                                voluntary     termination       of     a      litigation        has     drastic
                                consequences. It is severing one's hands for all times to
                                come. To avoid any injustice, the right of a litigant to
                                change the intent should be saved to conserve any possible
                                lawful claim, till an order terminating the litigation is
                                formally passed by the Court. This would in no way
                                prejudice any right of the defendant, and the damage if any,
                                can be rectified by the Court while passing the formal order.
                                The procedure, therefore, would enure to the benefit of both
                                parties. The Court should, however, at the very outset, if
                                such an application is filed, proceed to decide the same so
                                that   it   does    not     leave    the   parties     in       a     state   of
                                indecisiveness.      This    would     also     help       in    terminating
                                unnecessary litigation.”




                            18. Thus, the right to withdraw a claim is available in almost an

                      absolute form subject to and hedged by the limitations referred to in

                      the said decisions.          As to what is absolute withdrawal has also been

                      considered in a later judgment cited by the learned counsel for the

                      appellant in the case of Anurag Mittal v. Shaily Mishra Mittal,

                      (2018) 9 SCC 691, where this issue was discussed in paragraphs

                      (17) and (18), which are extracted herein under:



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                                “17. The High Court of Bombay in Anil Dinmani Shankar
                                Joshi v. Panvel Municipal Council, 2003 SCC OnLine Bom
                                24,: AIR 2003 Bom 238, followed the judgment of this Court
                                in Shiv Prasad v. Durga Prasad, (1975) 1 SCC 405 and held
                                that the said judgment is applicable to suits also. The High
                                Court recognised the unconditional right of the plaintiff to
                                withdraw his suit and held that the withdrawal would be
                                complete as soon as the plaintiff files his purshis of
                                withdrawal.



                                18. Order 23 Rule 1(1) CPC enables the plaintiff to abandon
                                his suit or abandon a part of his claim against all or any of
                                the defendants. Order 23 Rule 1(3) CPC requires the
                                satisfaction of the Court for withdrawal of the suit by the
                                plaintiff in case he is seeking liberty to institute a fresh suit.
                                While observing that the word abandonment in Order 23
                                Rule 1(1) CPC is “absolute withdrawal” which is different
                                from the withdrawal after taking permission of the court,
                                this Court held as follows K.S. Bhoopathy v. Kokila, (2000)
                                5 SCC 458] , SCC pp. 463-64, para 12:
                                    '12. The law as to withdrawal of suits as enacted in
                                    the present Rule may be generally stated in two
                                    parts:
                                    (a) a plaintiff can abandon a suit or abandon a part
                                    of his claim as a matter of right without the
                                    permission of the court; in that case he will be
                                    precluded from suing again on the same cause of
                                    action. Neither can the plaintiff abandon a suit or a


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                                  part of the suit reserving to himself a right to bring
                                  a fresh suit, nor can the defendant insist that the
                                  plaintiff must be compelled to proceed with the
                                  suit; and
                                  (b) a plaintiff may, in the circumstances mentioned
                                  in sub-rule (3), be permitted by the court to
                                  withdraw from a suit with liberty to sue afresh on
                                  the same cause of action. Such liberty being
                                  granted by the court enables the plaintiff to avoid
                                  the bar in Order 2 Rule 2 and Section 11 CPC.'”




                            19. In the present case, in our opinion, the appellant was

                      seeking judicial review on the principles of administrative law, and the

                      present proceedings in relation to an award of tender, which may have

                      been on erroneous grounds or otherwise, with which we are not

                      concerned, but the fact remains that at the intermediate stage of the

                      proceedings before the learned Single Judge, the order dated

                      14.11.2019 does take notice of the pendency of an application before

                      the Advance Ruling Authority and it was left open to the said authority

                      to decide the said application, which was not being decided by the

                      Advance Ruling Authority and was kept pending till the matter was

                      finally heard.




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                            20. Mr.Saffiq, learned counsel has clearly submitted that

                      normally in such matters when a writ petition or any other such

                      proceeding is pending before the High Court, the Advance Ruling

                      Authority awaits the disposal thereof and, therefore, the Advance

                      Ruling Authority had not proceeded to dispose of the matter. It is thus

                      clear that in spite of the observation of the Court on 14.11.2019, the

                      Advance Ruling Authority had kept the matter pending and this aspect

                      of the matter has not been taken into consideration by the learned

                      Single Judge while assuming that the appellant had unnecessarily

                      pursued the writ petition before this Court. In our opinion, there was a

                      justification, yet the appellant, in his wisdom, rightly instructed the

                      counsel to withdraw the writ petition, which endorsement was made in

                      open court.



                            21. It is the contention of the learned counsel that the Court did

                      not refuse permission when the endorsement was made and the

                      counsel was under the impression that the same would be considered

                      favourably in the circumstances indicated above, but the appellant was

                      taken by surprise when the writ petition came to be dismissed, that

                      too even with the imposition of Rs.5 Lakhs costs and refusing


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                      permission to withdraw the writ petition and liberty to pursue his

                      application before the Advance Ruling Authority.



                            22. On the said issue, we find that the learned Single Judge in

                      order to draw a curtain on the litigation at that stage had already been

                      offered an opportunity to dismiss the writ petition as withdrawn.    In

                      our view, once such a request has been made, and unless there are

                      any unrepresented third party rights that may be affected, or any of

                      the contingencies mentioned in the judgments referred to herein above

                      exist, it is always ordinarily an acceptable position that the Court

                      should not proceed to adjudicate the matter and permit withdrawal on

                      such conditions that may be necessary.



                            23. In the instant case, we find no party unrepresented in the

                      litigation being affected by the appellant seeking liberty to pursue his

                      application before the Advance Ruling Authority.    To this extent, the

                      fourth respondent cannot have any objection, in as much as he has no

                      locus to question the moving of an application by the appellant before

                      the Advance Ruling Authority and pursuing the same, which application




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                      admittedly was not disposed of due to the pendency of the writ petition

                      itself.



                                24. In such circumstances, we also do not find any valid reason

                      for   imposing     costs    on     the   appellant.      We   are    making     these

                      observations       only    in   relation    to   the   appellant    who   had    filed

                      W.P.No.24412 of 2019, which petition, in the facts narrated above,

                      stands on a different footing from the other writ petition, where the

                      petitioner does not appear to have filed any appeal questioning the

                      impugned judgment.



                                25. The appellant, therefore, had a right to withdraw the writ

                      petition     and   having       exercised   that   right,   there   was   no    legal

                      impediment in granting permission to the appellant to withdraw the

                      writ petition.      We, therefore, do not find the directions and the

                      observations made in paragraphs (41) and (42) of the impugned

                      judgment to be justified on the peculiar facts and circumstances of the

                      present case, as indicated above, and the same are also not supported

                      in law, as the withdrawal was in tune with the legal provisions that

                      have been enunciated in the judgments referred to above.                         We,


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                      therefore, allow the appeal only to the extent that paragraphs (41) and

                      (42) in so far as the present appellant is concerned would stand set

                      aside.



                               The appeal is allowed and the writ petition stands dismissed as

                      withdrawn, without prejudice to the right of the appellant to pursue his

                      application       before    the   Advance   Ruling   Authority.   No   costs.

                      Consequently, C.M.P.No.9761 of 2020 is closed.




                                                                    (A.P.S., CJ.)      (S.K.R., J.)
                                                                                09.09.2020
                      Index         :       Yes
                      sasi




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                      To:

                      1     The Tamil Nadu Medical Service Corporation
                            (A Government of Tamil Nadu undertaking)
                            No.417 Pantheon Road Egmore
                            Chennai - 600 008.

                      2     The Director of Medical Education
                            Directorate of Medical Education
                            Kilpauk, Chennai - 10.

                      3     The Assistant Commissioner GST
                            Chennai North Commissionerate
                            No.2054, I Block, Newry Towers
                            12th Main Road, 2nd Avenue
                            Anna Nagar, Chennai - 600 040.

                      4     The Assistant Commissioner (CT)
                            State GST, Koyambedu GST Circle
                            CMDA Administration Building
                            2nd Floor, Koyambedu
                            Chennai - 600 107.

                      5     Tamil Nadu Advance Ruling Authority
                            PAPJM Buildings, II Floor
                            No.1, Greams road
                            Chennai.




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                                    THE HON'BLE CHIEF JUSTICE
                                                 AND
                                SENTHILKUMAR RAMAMOORTHY,J.

(sasi) W.A.No.711 of 2020 09.09.2020 _______ Page 33 http://www.judis.nic.in