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[Cites 14, Cited by 0]

Madras High Court

Tvl.Safire Lithographers vs The State Of Tamil Nadu on 3 March, 2025

Author: Anita Sumanth

Bench: Anita Sumanth, R. Hemalatha

    2025:MHC:604
                                                                                        WP No. 27392 of 2010 etc. batch




                                   IN THE HIGH COURT OF JUDICATURE AT MADRAS

                                                   DATED: 03-03-2025

                                                           CORAM

                                  THE HONOURABLE DR JUSTICE ANITA SUMANTH
                                                   AND
                                  THE HONOURABLE MRS JUSTICE R. HEMALATHA

                                   WP Nos. 27392 & 27393 of 2010, WP No.3619 of 2009,
                                    WP.No.20362 of 2007 & WP.No.9007 of 2008 and
                                   MP.Nos.1 & 1 of 2010 & MP.Nos.1 of 2008 & 1 of 2009

                WP No. 27392 of 2010
                1. Tvl.Safire Lithographers
                Rep.By Its Proprietor. A.Gunasekaran, No.16
                (old No.31), Balaji Nagar 1st Street,
                Royapettah, Chennai-14.

                                                                                        Petitioner(s)

                                                               Vs

                1. The State Of Tamil Nadu
                Rep.By The Secretary To Government,
                Commercial Taxes And Registration
                Department, Fort St.George, Chennai-9.

                2.The Assistant Commissioner
                (c.T), Royapettah-ii Assessment Circle,
                Chennai.

                3.The Assistant Registering
                Authority, Regional Transport Office,
                Chennai South East, Mandaiveli, Chennai-
                28.

                                                                                        Respondent(s)

https://www.mhc.tn.gov.in/judis               ( Uploaded on: 06/03/2025 04:09:52 pm )
                                                                                    WP No. 27392 of 2010 etc. batch


                WP No. 3619 of 2009
                1. M/s.Anamallais Bus Transport
                Private Limited, Rep. By Its Authorised
                Signatory N.Shanmugasundaram, Sakthi
                Nilayam, No.92, Nachimuthu Gounder St.,
                Pollachi.

                                                                                    Petitioner(s)
                                                                Vs
                1. State Of Tamil Nadu
                Rep. By Its Secretary To Government,
                Commercial Taxes And Registration
                Department, Fort St. George, Chennai - 9.

                2.The Assistant Commisioner (ct)
                (fac), Pollachi (east), Pollachi.

                                                                                    Respondent(s)
                WP No. 20362 of 2007
                1. The R.P.Motors, Rep. By Its
                Managing Partner P.Saravanan, Palghat Road,
                Pollachi

                                                                                    Petitioner(s)
                                                                Vs
                1. The State Of Tamilnadu
                Rep. By The Secretary To Govt., Commercial
                Taxes And Religious Endowments Dept.,
                Chennai-09

                2.The Deputy Commercial Tax
                Officer, Pollachi (west), Pollachi

                                                                                    Respondent(s)
                WP No. 27393 of 2010
                1. Tvl.Safire Lithographers
                Rep.By Its Proprietor. A.Gunasekaran, No.16
                (old No.31), Balaji Nagar 1st Street,
                Royapettah, Chennai-14.

https://www.mhc.tn.gov.in/judis                ( Uploaded on: 06/03/2025 04:09:52 pm ) Petitioner(s)
                                                                                         WP No. 27392 of 2010 etc. batch




                                                                  Vs
             1. The State Of Tamil Nadu
             Rep.By The Secretary To Government,
             Commercial Taxes And Registration
             Department, Fort St.George, Chennai-9.

             2.The Assistant Commissioner
             (c.T), Royapettah-ii Assessment Circle,
             Chennai.

             3.The Assistant Registering
             Authority, Regional Transport Office,
             Chennai South East, Mandaiveli, Chennai-
             28.

                                                                                         Respondent(s)
             WP No. 9007 of 2008
             1. M/s Hotel Saravana Bhavan,
             Rep. By Its Partner Mr.R. Saravanan, Having
             Registered Offie At No.19, Vadapalani
             Andavar Koil St., Vadapalani, Chennai-26,
             Branch Office At No

                                                                                         Petitioner(s)

                                                                  Vs
             1. The State Of Tamilnadu Rep.
             By The Secretary To Govt., Commercial
             Taxes And Religious Endowments Dept.,
             Fort St. George, Chennai-9

             2.The Assistant Commissioner (ct
             Administration, Chennai (central)division,
             Office Of The Deputy Commissioner (ct),
             Chennai (central) Division, Papjm Buildings,
             Greams Road,

               3.The Commercial Tax Officer
               Vadapalani - I Asst. Circle, 10c, Razack
               Garden Road, Chennai -
https://www.mhc.tn.gov.in/judis                ( Uploaded on: 06/03/2025 04:09:52 pm )
                                                                             WP No. 27392 of 2010 etc. batch




            4.The Regional Transport
            Officer, Chennai (east), Pulianthope,
            Chennai

                                                                             Respondent(s)
                                                WP No. 27392 of 2010

            Prayer: Writ Petition filed under Article 226 of the Constitution of India praying to issue a
            writ of declaration declaring the provisions of the Tamil Nadu Tax on Entry of Motor
            Vehicles into Local Areas Act, 1990, as ultra vires Article 14, 19(1)(g), 301 and 304(a) and
            (b) of the Constitution of India and being non-compensatory in nature in view of the recent
            finding rendered by the First bench of the Honble High Court in the case of MR.R Gandhi Vs
            State of Tamil Nadu reported in 13 VST 390 following the law declared by the Supreme
            Court of India in the judgment reported in 145 STC 544 and therefore unenforceable and of
            no effect in so far as the petitioner herein is concerned.

                                                 WP No. 3619 of 2009
            Prayer: Writ Petition filed under Article 226 of the Constitution of India praying to issue a
            writ of declaration declaring that the nature of a writ declaring that section 2 (d), section 2(g)
            and section 3 of the Tamil Nadu Tax on Entry of Motor Vehicles into Local Areas Act, 1990
            in so far as it relates to imports made by the petitioner herein a sultra vires Articles 14,
            19(1)(a), 19(1)(g), 301, 304(a) and 204(b) of the Constitution of India and also not a
            compensatory or regulatory tax in view of the law laid down by the Honourable Supreme
            Court in the case of Jindal Strainless Steel and another V. State of haryana and others
            reproted in 145 STC 544 and therefore unenforceable and of no effect in so far as the
            petitioner is concerned.

                                                 WP No. 20362 of 2007
            Prayer: Writ Petition filed under Article 226 of the Constitution of India praying to issue a
            writ of declaration declaring that section 2(d), section 2(g) and section 3 of the Tamil Nadu
            tax entry of motor vehicle into local areas act 1990 in so far it relates two wheelers as ultra
            vires articles 14, 19(1)(a), 19(1)(g), 301, 304(a) and 304(b) of the constitution of india and
            also not a compensatory or regulatory tax in view of the law laid down by the supreme court
            in the case of Jindal Stainless steel and another V. State of Haryana and others reported in
            145 STC 544 and therefore enforceable and of no effect in so far as the petitioner is
            concerned.

                                                   WP No. 27393 of 2010
               Prayer: Writ Petition filed under Article 226 of the Constitution of India praying to issue a
https://www.mhc.tn.gov.in/judis               ( Uploaded on: 06/03/2025 04:09:52 pm )
               writ of declaration declaring the provisions of the Tamil Nadu Tax on Entry of Motor
                                                                                             WP No. 27392 of 2010 etc. batch


                Vehicles into Local Areas Act, 1990, as ultra vires Article 14, 19(1)(g), 301 and 304(a) and
                (b) of the Constitution of India and being non-compensatory in nature in view of the recent
                finding rendered by the First bench of the Honble High Court in the case of MR.R Gandhi Vs
                State of Tamil Nadu reported in 13 VST 390 following the law declared by the Supreme
                Court of India in the judgment reported in 145 STC 544 and therefore unenforceable and of
                no effect in so far as the petitioner herein is concerned.

                                                       WP No. 9007 of 2008
                Prayer: Writ Petition filed under Article 226 of the Constitution of India praying to issue a
                writ of declaration declaring the provisions of the Tamil Nadu on Entry of Motor Vehicles
                into Local Areas Act, 1990, as ultra vires Article 14, 19(1)(9), 301 and 304 (a) and (b) of the
                Constitution of India and being non-compensatory in nature in view of the recent finding
                rendered by the Division Bench of the Honourable High court in W.P.No. 15690 of 1996 and
                batch of cases vide order dated 10.7.2007 following the law declared by the Supreme Court
                of India in the judgment reported in 145 STC 544 and therefore unenforceable and of no
                effect in so far as the petitioner herein is concerned.

                                                       WP No. 27392 of 2010
                                  For Petitioner(s):      M/s.P.Radhakrishnan

                                  For Respondent(s):         Mr. Haja Naziruddin, AAG Assisted
                                                             By Mr. V. Prashanth Kiran GA For
                                                             Respondents

                                                     COMMON ORDER

(Order of the Court was made by Dr.Anita Sumanth J.) Mr.P.Radhakrishnan, learned counsel appearing for the petitioners and Mr.Haja Naziruddin, learned Additional Advocate General for Mr.V.Prashanth Kiran, learned Government Advocate for the respondents, bring to the notice of this Court that the prayers for Declaration that various provisions of the Tamil Nadu Tax on Entry of Motor Vehicles into Local Areas Act, 1990 are ultra vires Articles 14, 19(1)(a), 19(1)(g), 301, 304(a) and 304(b) of the Constitution of India is not liable to be granted, in light of the authoritative pronouncements of the Supreme Court in Jindal Stainless Limited and Another v. State of https://www.mhc.tn.gov.in/judis ( Uploaded on: 06/03/2025 04:09:52 pm ) WP No. 27392 of 2010 etc. batch Haryana and Others [(2017) 12 SCC 1] and State of Kerala and Others v. Fr. William Fernandez and Others [(2021) 11 SCC 7055].

2.In light of the above, these writ petitions are dismissed. No costs. Connected miscellaneous petitions are closed.

                                                                                  [A.S.M.,J.]     [R.H.,J.]
                                                                                           03-03-2025

             vs
             Index:No
             Speaking order
             Neutral Citation:Yes

                                                     WP No. 27392 of 2010
             To

             1.The State Of Tamil Nadu

Rep.By The Secretary To Government, Commercial Taxes And Registration Department, Fort St.George, Chennai-9.

2.The Assistant Commissioner (c.T), Royapettah-ii Assessment Circle, Chennai.

3.The Assistant Registering Authority, Regional Transport Office, Chennai South East, Mandaiveli, Chennai-

28. WP No. 3619 of 2009 To

1.State Of Tamil Nadu Rep. By Its Secretary To Government, Commercial Taxes And Registration https://www.mhc.tn.gov.in/judis ( Uploaded on: 06/03/2025 04:09:52 pm ) Department, Fort St. George, Chennai - 9. WP No. 27392 of 2010 etc. batch

2.The Assistant Commisioner (ct) (fac), Pollachi (east), Pollachi.

WP No. 20362 of 2007

To

1.The State Of Tamilnadu Rep. By The Secretary To Govt., Commercial Taxes And Religious Endowments Dept., Chennai-09

2.The Deputy Commercial Tax Officer, Pollachi (west), Pollachi WP No. 27393 of 2010 To

1.The State Of Tamil Nadu Rep.By The Secretary To Government, Commercial Taxes And Registration Department, Fort St.George, Chennai-9.

2.The Assistant Commissioner (c.T), Royapettah-ii Assessment Circle, Chennai.

3.The Assistant Registering Authority, Regional Transport Office, Chennai South East, Mandaiveli, Chennai-

28. WP No. 9007 of 2008 To

1.The State Of Tamilnadu Rep.

By The Secretary To Govt., Commercial Taxes And Religious Endowments Dept., Fort St. George, Chennai-9 https://www.mhc.tn.gov.in/judis ( Uploaded on: 06/03/2025 04:09:52 pm ) WP No. 27392 of 2010 etc. batch

2.The Assistant Commissioner (ct Administration, Chennai (central)division, Office Of The Deputy Commissioner (ct), Chennai (central) Division, Papjm Buildings, Greams Road,

3.The Commercial Tax Officer Vadapalani - I Asst. Circle, 10c, Razack Garden Road, Chennai -

4.The Regional Transport Officer, Chennai (east), Pulianthope, Chennai https://www.mhc.tn.gov.in/judis ( Uploaded on: 06/03/2025 04:09:52 pm ) WP No. 27392 of 2010 etc. batch Dr.ANITA SUMANTH J.

AND R.HEMALATHA J.

vs WP Nos. 27392 & 27393 of 2010, WP No.3619 of 2009, WP.No.20362 of 2007 & WP.No.9007 of 2008 03-03-2025 https://www.mhc.tn.gov.in/judis ( Uploaded on: 06/03/2025 04:09:52 pm )