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[Cites 20, Cited by 2]

Delhi High Court

Shri Nand Kishore Garg & Anr. vs Government Of Nct Of Delhi & Ors. on 18 February, 2011

Author: Dipak Misra

Bench: Chief Justice, Manmohan

*             HIGH COURT OF DELHI AT NEW DELHI

                              Judgment Reserved on : 11th February, 2011
%                             Judgment Pronounced on: 18th February, 2011


+      WP(C) No.4821/2010

       SHRI NAND KISHORE GARG & ANR.               ..... Petitioners
                 Through: Mr.Laliet Kumar with Mr.Deepak Vohra,
                          Advocates
                          Mr.Jayant Bhushan, Sr. Advocate with
                          Ms.Pyoli, Advocate for the Intervenor.
            Versus

       GOVERNMENT OF NCT OF DELHI & ORS.       ....Respondents
              Through: Mr.Goolam E. Vahanvati, Attorney
                       General along with Mr.Atul Nanda,
                       Advocate for Union of India.
                       Mr.Dushyant Dave, Sr. Advocate with
                       Mr.N.Waziri and Ms.Neha Kapoor,
                       Advocates for the Respondent No.1.
                       Mr.Parag P. Tripathi, ASG with Mr.H.S.
                       Chandhoke and Mr.Kunal Bahri,
                       Ms.Purnima Sapra, Advocates for the
                       Respondent No.2.
                       Mr.V.P. Singh with Mr.Aashish Gupta,
                       Advocates for the Respondent No.3.
                       Mr.Sudhir Nandrajog, Sr. Advocate with
                       Mr.Amit Kumar and Mr.Anupam Varma,
                       Advocates for the Respondent No.4.
                       Dr.A.M.Singhvi, Sr.Advocate with
                       Mr.V.P. Singh, Mr.Anuj Berry and
                       Mr.Jaiveer Shergil, Advocates for the
                       Respondent No.5.

       CORAM:
       HON'BLE THE CHIEF JUSTICE
       HON'BLE MR. JUSTICE MANMOHAN
1. Whether reporters of the local papers be allowed to see the judgment? Yes
2. To be referred to the Reporter or not?                                    Yes
3. Whether the judgment should be reported in the Digest?                    Yes
WP(C) No. 4821/2010                                                   Page 1 of 19
 DIPAK MISRA, CJ


       In this public interest litigation the petitioner describing himself as

pro bono publico has prayed for issue of a writ of mandamus commanding

the respondent No.2, Delhi Electricity Regulatory Commission (for short

„the Commission‟), to issue the tariff approved by it on 28/29.4.2010 and

pass such other order / orders as may be deemed fit in the facts and

circumstances of the case.


2.     At the very outset, we may state with profit that various assertions

and asseverations have been made with regard to the issues relating to

finalization of the tariff by the Commission under the provisions of The

Electricity Act, 2003 (for brevity „the 2003 Act‟), the illegality committed

by the Government of National Capital Territory of Delhi in asking the

Commission not to issue the tariff and further how the consumers have

been affected by non-issuance of the tariff order. But after impleadment of

certain respondents, namely, BSES Yamuna Power Ltd., BSES Rajdhani

Power Ltd. and North Delhi Power Ltd. the question, apart from other

issues, that fundamentally cropped up whether the State Government could

have passed the order in the manner it has done in exercise of power under

Section 108 of the 2003 Act.


3.     In this regard, we think it apposite to reproduce the relevant

submissions advanced on 9.9.2010:

              "The submission of Mr. Laliet Kumar, learned counsel
              for petitioner, is that the State Government could not

WP(C) No. 4821/2010                                             Page 2 of 19
               have intervened after the tariff was determined by the
              Commission as the same is not permissible under any of
              the provisions of the statute. The learned counsel for
              the petitioner further submitted that the tariff fixation
              does not come within the ambit and sweep of a policy
              decision and further after a decision has been taken by
              the Commission, the State Government has no authority
              to issue any direction or intervene in the matter.

                     Quite apart from that, it has been submitted by
              Mr. Laliet Kumar that the letter dated 4th May, 2010
              issued by the State Government does not meet
              the requisite criteria of a policy decision, though the
              same has been couched in a different language. To
              bolster the said aspect, the learned counsel for
              the petitioner has commended us to the provisions
              contained in Sections 61, 62, 64 and 92 of the
              Electricity Act, 2003 (for brevity "the Act").

                    Mr.Harish N. Salve, learned senior counsel
              appearing for NDPL, and Mr.Neeraj Kishan Kaul,
              learned senior counsel appearing for BSES Rajdhani
              Power Ltd., contended that the State Government has
              the power to issue directions as is evincible from
              Section 108 of the Act. Section 108 reads as under:-

                      "108. Directions by State Government:---(1) In
                      the discharge of its functions, the State
                      Commission shall be guided by such directions in
                      matters of policy involving public interest as the
                      State Government may give to it in writing.

                      (2) If any question arises as to whether any
                      such direction relates to a matter of policy
                      involving public interest, the decision of the State
                      Government thereon shall be final."

                     The learned senior counsel have also drawn
              inspiration from Section 86(4) of the Act which reads as
              under:-

                      "86. Functions of State Commission:
                      xxxx        xxxx         xxxx       xxxx

                      (4) In discharge of its functions, the State
                      Commission shall be guided by the National


WP(C) No. 4821/2010                                                Page 3 of 19
                       Electricity Policy, National Electricity Plan and
                      Tariff Policy published under section 3."

                     It is submitted by Mr. Salve that if both the
              provisions are read in a purposeful and harmonious
              manner, it would convey that the State Government
              has the authority to issue such directions which fall in
              the realm of policy decision involving public interest
              and fixation of tariff or determination of tariff in
              accordance with National Electricity Policy, National
              Electricity Plan and Tariff Policy as published under
              Section 3 of the Act do come within the concept of
              policy.

                     The learned senior counsel would further submit
              that the „public interest‟ cannot be narrowly construed
              in the conceptual canvas of the Act inasmuch as in a
              democratic body polity, the State Government has a role
              to see that there is electricity supply regard being had
              to the industrial growth as well as protection of the
              consumers.

                     Mr. Najmi Waziri, learned standing counsel for
              GNCT of Delhi, would contend that if the
              communication of the State Government is read in an
              apposite manner, it is clear as crystal that the State
              Government was seeking clarification from the
              Commission and pending clarification had directed not
              to issue the tariff order."


4.       Thereafter, this Court by order dated 27.10.2010 sought the

assistance of the learned Attorney General to address the Court on the first

issue.     It is appropriate to note that learned Attorney General only

addressed this Court with regard to the first issue and the matter was

adjourned for adjudication on other issues.


5.       When the matter was listed on the adjourned dates arguments were

heard on other issues but finally it was felt while hearing the matter on

11.2.2011 that the first issue should be decided and thereafter the other

WP(C) No. 4821/2010                                             Page 4 of 19
 issues should be taken up. We may note with profit learned counsel for the

parties very fairly acceded to the same.


6.     At this juncture, it is obligatory on our part to mention that

Mr.Dushyant Dave, learned senior counsel along with Mr.N. Waziri,

learned standing counsel appearing for the GNCTD submitted that the State

Government has taken a decision to withdraw the communication sent to

the Commission. Had the same been stated at the very initial stage the

matter would have been absolutely different. As a colossal grievance was

made and arguments were canvassed at length and we had sought the

assistance of the learned Attorney General who addressed us at length, we

have thought it seemly to delve into the said issue and answer the same.

We may also note with profit that we had indicated it to Mr.Dave and

Mr.Waziri and, therefore, learned counsel for the GNCTD while reiterating

the stand of withdrawal of the communication also addressed the Court on

merits on the said score.


7.     Mr. Goolam E. Vahanvati, learned Attorney General being assisted

by Mr.Atul Nanda, submitted that the nature of communication that has

been made does not come within the ambit and sweep of Section 108 of the

2003 Act. It is urged by him that if Section 108 of the 2003 Act is

appropriately and appositely interpreted it would clearly convey that the

State Government has no jurisdiction to pass such an order as that would

tantamount to interference in the statutory functioning of the Commission.

It is contended by him the words used under Section 108 of the 2003 Act

WP(C) No. 4821/2010                                          Page 5 of 19
 are that "the State Commission shall be guided by such directions in

matters of policy involving public interest" and, therefore, the State

Government can only issue guidelines which would relate to a larger public

interest in the field of social structuralism or any kind of benefit to a class

but by no stretch of imagination can issue a command to the Commission

not to issue a tariff order. It is his further submission that policy and public

interest are inseparably connected and the policy must reflect such larger

public interest by which the Commission shall be guided. It is urged by

him that Section 86 of the Act sets the guidance / guidelines for functioning

of the Commission and the said provision does not confer any power on the

State Government to interdict. Learned Attorney General further proponed

that the Section 108 of the 2003 Act is almost similar to Section 78A of the

Electricity (Supply) Act, 1948 (for short „the 1948 Act‟) and the

interpretation placed on the said provision in many an authority would have

application for understanding the contour and sweep of the present

provision. To buttress the said submission, he has taken us through the

scheme of the Act and commended to the authorities in Indian Metal &

Ferro Alloys Ltd. v. State of Orissa & Ors., (1987) 3 SCC 189, M/s.Real

Food Products Ltd. and others v. Andhra Pradesh State Electricity Board

and others, (1995) 3 SCC 295, Ester Industries Ltd. v. U.P. State

Electricity Board & Ors., (1996) 11 SCC 199, Pawan Alloys and Casting

Pvt. Ltd. v. U.P. State Electricity Board & Ors., (1997) 7 SCC 251 and

Chittoor Zilla Vyavasay Adarula Sangham v. A.P. State Electricity Board

& Ors., (2001) 1 SCC 396. He has also drawn inspiration from a passage

WP(C) No. 4821/2010                                               Page 6 of 19
 in Laker Airways Ltd. v. Department of Trade, (1979) 2 WLR 234

especially wherein Lord Denning M.R. has adverted to the concept of

guidance and directions.


8.     Mr.Dave, learned senior counsel along with Mr.Waziri, learned

standing counsel for the GNCTD submitted that Section 108(1) has been

broadly couched and, therefore, the authorities under Section 78A would

not be applicable and deserve to be distinguished. Learned senior counsel

has submitted that Section 108 of the 2003 Act uses the words "involving

public interest" and, hence, it has a dynamic concept which has to be

understood regard being had to the purpose / action / interest which would

subserve the interest of the public at large at the relevant time. What would

constitute public interest would depend on the facts and circumstances of

the case obtaining at the time when it is determined and the same has to be

left to the executive. It is urged that if sub-section (2) of 108 of 2003 Act is

purposively understood it would be clear as day that the Parliament has

wisely left the decision of defining and determining public interest to the

State Government and whether a direction relates to a matter of policy

involving public interest is in the domain of the State Government and the

said decision is final. Learned senior counsel has commended us to the

decisions in Kusumam Hotels v. Kerala SEB, (2008) 13 SCC 213, A.P.

State Electricity Board Vidyut Soudha & Ors. v. Gowthami Solvent Oils

& Anr., AIR 1991 A.P. 141, Management of Fertilizer Corp. of India v.

The Workmen, (1969) 2 SCR 706, Food Corporation of India and Ors. v.


WP(C) No. 4821/2010                                               Page 7 of 19
 Bhanu Lodh and Ors. (2005) 3 SCC 618, G.D. Zalani and another etc. v.

Union of India and others, 1995 Supp (2) SCC 512, Pure Helium India

Pvt. Ltd. v. Oil and Natural Gas Commission, (2003) 8 SCC 593,

M/s.Real Food Products Ltd. (supra), Hotel Venus International v. State

of Andhra Pradesh and others, AIR 1998 AP 78 and Hindustan Zinc Ltd.

v. APSEB, 1991 (3) SCC 299 and also placed reliance on certain

paragraphs of the decisions which have been placed reliance upon by the

learned Attorney General.


9.     Mr.Dave, learned senior counsel has also drawn inspiration from the

statements of objects and reasons of 2003 Act. It is also contended by him

that the basic purpose of the GNCTD while issuing the communication in

question was to ensure that in the public interest, the National Tariff Policy

should be duly adhered to by the DERC in fixing power tariff. It was the

intention of the State that DERC should be guided by the National Tariff

Policy.


10.    The question that emerges for consideration is whether the

communication dated 4.5.2010 could have been made in exercise of power

vested in the State Government under Section 108 of the 2003 Act. Section

108 of the 2003 Act reads as under:

              "108. Directions by State Government:---(1) In the
              discharge of its functions, the State Commission shall
              be guided by such directions in matters of
              policy involving public interest as the State
              Government may give to it in writing.



WP(C) No. 4821/2010                                             Page 8 of 19
               (2) If any question arises as to whether any such
              direction relates to a matter of policy involving public
              interest, the decision of the State Government thereon
              shall be final."


11.    Section 78A of the 1948 Act reads thus:

              78A. Directions by the State Government - (1) in the
              discharge of its functions, the Board shall be guided by
              such directions on questions of policy as may be given
              to it by the State Government.

              (2) If any dispute arises between the Board and the
              State Government as to whether a question is or is not a
              question of policy, it shall be referred to the Authority
              whose decision thereon shall be final."


12.    In Indian Metal & Ferro Alloys Ltd. (supra), while interpreting

Section 22-B of the Electricity Act, 1910, the Apex Court has held thus:

              "It appears to us to be clear on a reading of Section 22-
              B of the Act that what is contemplated by it is that the
              State Government should only lay down policy
              guidelines to be adopted by the Board for regulating
              supply, jurisdiction (sic distribution), consumption or
              use of energy. The implementation of the policy after
              working out the details is a matter to be carried out by
              the Board. It is therefore somewhat strange that the
              State Government has taken upon itself the task of
              allocating the quantum of power that may be consumed
              by the different industrial units mentioned in the
              Annexures to the Government Orders passed in respect
              of the years 1984-85, 1985-86 and 1986-87 under
              Section 22-B of the Act. However, the High Court is in
              our opinion right in holding that under the aforesaid
              section, the Government may for the purposes of
              securing equitable distribution of energy regulate its
              consumption or use and decide as a matter of policy
              whether the benefit of clubbing should be allowed to the
              consumers of energy...."




WP(C) No. 4821/2010                                             Page 9 of 19
 13.    In Chittoor Zilla Vyavasay Adarula Sangham (supra), the Apex

Court came to hold as follows:


              "22. It is necessary first to examine the periphery of
              the statutory fields within which the Board and the State
              Government have to function. Admittedly both are
              statutory functionaries under the Central Act. They
              have to perform their obligations within the limits they
              have been entrusted with. Section 78-A empowers the
              State Government to issue directions to the Board on
              the question of policy, on the other hand the Board has
              to perform its statutory obligations under the said Act
              and with reference to the fixation of tariff it has to act in
              terms of what is contained in Sections 49 and 50. But
              this field of policy direction is not unlimited. There
              cannot be any policy direction which pushes the Board
              to perform its obligations beyond the limits of the said
              two sections. Any policy direction, which in its due
              performance keeps the Board within its permissible
              statutory limitations would be binding on the Board.
              So, both the State and the Board have to maintain their
              cordiality and coordination in terms of the statutory
              sanctions. If any policy direction pushes the Board in
              its compliance beyond statutory limitations, it cannot be
              a direction within the meaning of Section 78-A. It is
              significant that the opening words of Section 78-A are,
              "in the discharge of its functions, the Board shall be
              guided by such directions". So, the direction of the
              State is for the guidance to the Board, in the discharge
              of its functions. Thus this direction has also limitation
              to give such direction which will subserve in
              performing its statutory obligation. We would be
              returning later to test, if direction to charge tariff at the
              rate of Rs.50 per HP per annum would have been
              followed by the Board, whether it would have travelled
              beyond Section 59.
              xxx
              xxx
              25. Now, we proceed to examine what this Court
              held in the Real Food Products Ltd.1 This Court
              examined the nature and effect of the direction given by
              the State Government under Section 78-A. It was
              examined in the context of charging a flat rate per H.P.
              for agricultural pumpsets. It holds the view expressed
WP(C) No. 4821/2010                                                Page 10 of 19
               by the State on a question of policy to be followed by
              the Board in the context of Board‟s function under
              Sections 49 and 59 and other provisions of the Act.
              This Court held that the flat rate per HP for the
              agricultural pumpset was found acceptable by the
              Board. What does acceptable to the Board means? It
              only means it to be within the parameters of Sections 49
              and 59 of the Act. In other words, the Board has not to
              travel outside its obligations under Section 59. This
              decision records:
                      "However, in indicating the specific rate in a
                      given case the action of the State Government
                      may be in excess of the power of giving a
                      direction on the question of policy, which the
                      Board, if its conclusion be different, may not be
                      obliged to be bound by... If the view expressed
                      by the State Government in its direction exceeds
                      the area of policy, the Board may not be bound
                      by it unless it takes the same view on merits
                      itself.
                             ***    ***   ***    ***    ***   ***
                        At any rate, there is no material in the present
                      case to indicate that the flat rate indicated by the
                      State Government for the agricultural pumpsets
                      was so unreasonable that it could not have been
                      considered appropriate by the Board."


              Thus it is clear that the Board would not be bound to
              follow every policy direction. According to the Board,
              if tariff was charged at the rate of Rs. 50 per HP per
              annum, as per the direction in question, loss to the
              Board would have been to the extent of Rs. 1,553 crores
              for the year 1996-97. This would have gone contrary to
              the obligation cast on the Board under Section 59.
              Section 59 mandates the Board to leave such surplus not
              less than 3% of the revenue, after meeting all its
              expenses referred to therein. Thus Board has not to
              supply electricity at such rate to be in deficit, leaving no
              hope for its extensions for the benefit of persons living
              in an uncovered area. It is for this and other reason
              statute mandates Board to maintain this surplus in every
              year. If it has to perform this statutory obligation, how
              can it do so, if it follows any such direction which takes
              it away from it. It is true the Government can (sic has)

WP(C) No. 4821/2010                                                 Page 11 of 19
               to cater to the popular demand in order to earn its
              legitimate favour, give any such policy direction, but it
              should have to be within permissible limit."
                                                   [Emphasis supplied]


14.    In Real Food Products Ltd. & Ors. (supra), a three-Judge Bench of

the Apex Court has observed thus:


              "8. The only surviving question is with regard to the
              nature and effect of the direction given by the State
              Government under Section 78-A of the Act. The
              question has to be examined in the context of the facts
              of the present case which is confined to the charging of
              a flat rate per H.P. for agricultural pump-sets. The
              nature of the function of the board in fixing the tariffs
              and the manner of its exercise has been considered at
              length in the earlier decisions of this Court and it does
              not require any further elaboration in the present case.
              Section 78-A uses the expression "the Board shall be
              guided by such directions on questions of policy as may
              be given to it by the State Government". It does appear
              that the view expressed by the State Government on a
              question of policy is in the nature of a direction to be
              followed by the Board in the area of the policy to which
              it relates. In the context of the function of the Board of
              fixing the tariffs in accordance with Section 49 read
              with Section 59 and other provisions of the Act, the
              Board is to be guided by any such direction of the State
              Government. Where the direction of the State
              Government, as in the present case, was to fix a
              concessional tariff for agricultural pump-sets at a flat
              rate per H.P., it does relate to a question of policy which
              the Board must follow. However, in indicating the
              specific rate in a given case, the action of the State
              Government may be in excess of the power of giving a
              direction on the question of policy, which the Board, if
              its conclusion be different, may not be obliged to be
              bound by. But where the Board considers even the rate
              suggested by the State Government and finds it to be
              acceptable in the discharge of its function of fixing the
              tariffs, the ultimate decision of the Board would not be
              vitiated merely because it has accepted the opinion of
              the State Government even about the specific rate. In
              such a case the Board accepts the suggested rate
WP(C) No. 4821/2010                                               Page 12 of 19
               because that appears to be appropriate on its own view.
              If the view expressed by the State Government in its
              direction exceeds the area of policy, the Board may not
              be bound by it unless it takes the same view on merits
              itself."
                                                  [Underlining is ours]


15.    In Pawan Alloys and Casting Pvt. Ltd. (supra), their Lordships of

the Apex Court have observed thus:


              "For the purpose of the present discussion we may
              proceed on the basis that while fixing general tariffs and
              making them subject to schemes of rebate, the Board
              exercises delegated legislative function flowing from
              the Statute. However once incentive rebate is granted in
              the general rate of tariffs on directions by State under
              Section 78A, the said incentive rebate offered by the
              Board would remain in the realm of exercise of
              statutory power-cum-duty. In the exercise of the same
              power the Board in its discretion can grant rebate in
              appropriate cases within the fore corners of Sections 49
              and 78A of the Act. Of course this exercise will be
              subject to legally permissible limits and subject to the
              said concessional rates being found reasonable on the
              touchstone of Article 14 of the Constitution of India. It
              is, therefore, not possible to countenance the submission
              of Shri Dave that there cannot be any promissory
              estoppel against the Board when it exercises its powers
              under Section 49(1) of the Act whatever may be the
              settings for exercise of this power and even if it is
              exercised as a part of a scheme of incentive package:
              required to be offered to new industries as enjoined on
              the Board as per statutorily binding directions issued by
              the State to the Board under Section 78A of the Act."
                                                  [Underlining is ours]


16.    In this context, we may fruitfully refer to the decision in Ester

Industries Ltd. (supra), wherein their Lordships of the Apex Court have

held thus:


WP(C) No. 4821/2010                                              Page 13 of 19
               "4. Section 78A(1) of the Act postulates that in the
              discharge of its functions, the Board shall be guided by
              such directions on questions of policy as may be given
              to it by the State Government. In other words, the
              Electricity Board has a statutory function to discharge in
              determination of the rates of tariff and terms and
              conditions subject to which the electrical energy be
              supplied to the consumers and enforcement thereof.
              This being a legislative policy, while exercising the
              power under Section 78A policy directions issued by
              the Government may also be taken into consideration by
              the Electricity Board which has a statutory duty to
              perform. But so long as the policy direction issued by
              the Government is consistent with the provisions of the
              Act and the tariff policy laid down by the Board, it may
              be open to the Board to either accept it or may not
              accept the directions as such. It is for the State
              Government to consider whether the Board has laid
              down the policy or whether the direction issued by the
              State Government has not been properly implemented."
                                                      [Emphasis added]


17.    In Hindustan Zinc Ltd. Etc. Etc. (supra), a three-Judge Bench of the

Apex Court while interpreting the provisions under the Electricity (Supply)

Act, 1948 has opined thus:


              "16. ... The question, therefore, reduces itself to this:
              Whether the failure of the Board to place the matter
              before and seek the advice of the Consultative Council
              on this question renders the revision of tariffs made by
              it invalid? The common premise for the purpose of this
              case that revision of tariffs by the Board is a question of
              policy may indicate that it would be open to the
              Consultative Council to advise the Board also on the
              question of revision of tariffs, and if such advice is
              given, then the Board must consider the same before
              taking the final decision. That, however, does not
              necessarily mean that where no such advice was taken
              from the Consultative Council or was rendered on
              account of the absence of any meeting of the
              Consultative Council during the relevant period, it
              would necessarily render invalid the revision of tariffs
              made by the Board."
WP(C) No. 4821/2010                                               Page 14 of 19
 18.    In Kusumam Hotels Pvt. Ltd. (supra), the Apex Court interpreted

Section 78-A(1) and (2) and held as under:


              "37. The State of Kerala in this case did not grant any
              concession by itself. The Central Government took a
              larger policy of treating tourism as an industry. A wide
              range of concessions were to be granted by way of one-
              time measure; some of them, however, had a recurring
              effect. So far as grant of benefits which were to be
              recurring in nature is concerned, the State exercises its
              statutory power in the case of grant of exemption from
              payment of building tax wherefor it amended the
              statute. It issued directions which were binding upon the
              Board having regard to the provisions contained in
              Section 78-A of the 1948 Act. The Board was bound
              thereby. The Board, having regard to its financial
              constraints, could have brought its financial stringency
              to the notice of the State. It did so. But the State could
              not have taken a unilateral decision to take away the
              accrued or vested right. The Board's order dated
              11.10.1999 in law could not have been given effect to.
              The Board itself kept the said notification in abeyance
              by reason of the order dated 8.11.1999."


19.    In this regard, we may fruitfully reproduce a passage from Laker

Airways Limited (supra). It is as follows:


              "The word "direction" in section 4 is in stark contrast
              with the word "guidance" in section 3. It is used again
              in section 24(2) and (6)(b) and section 28(2). It denotes
              an order or command which must be obeyed, even
              though it may be contrary to the general objectives and
              provisions of the statute. But the word "guidance" in
              section 3 does not denote an order or command. It
              cannot be used so as to reverse or contradict the general
              objectives or provisions of the statute....."


20.    Regard being had to the aforesaid pronouncement of law in the field,

the justifiability and the legal substantiality of the communication made by

WP(C) No. 4821/2010                                              Page 15 of 19
 the State has to be tested. As is demonstrable the State is entitled to change

or alter economic policies and the said decision has to be in public interest.

In the case at hand, the nature of directions issued by the State Government

has a different contour.        To appreciate the controversy in proper

perspective it is necessitous to reproduce the communication sent by the

State Government to the Commission:


              "The Secretary,
              Delhi Electricity Regulatory Commission,
              Viniyamak Bhawan,
              Shivalik, Malviya Nagar,
               New Delhi - 10 017

              Sir,

                    Through separate representations to the
              Government, the three distribution companies, BRPL,
              NDPL and BYPL have raised the issue of severe
              cash flow constraints affecting their ability to purchase
              power in 2010-11. A copy of this representation is
              enclosed. They have broadly drawn the attention of the
              Government on the following issues:

              1.      Ability to supply power contingent on Cost
                      Reflective Tariff.
              2.      Precarious Financial Position on Discoms.
              3.      Accumulation of revenue gaps beyond
                      sustainable levels.
              4.      Continuation of the practice of assuming higher
                      surplus for tariff fixation.
              5.      Power purchase cost/quantum.
              6.      Continuous recourse to addition debt to
                      finance operations, and
              7.      Critical need to additional financing.

              The issues raised by the Discoms are very serious and
              needs to be examined thoroughly so that the sustainable
              model of tariff setting as prescribed under section 61
              and 62 of the Electricity Act is not jeopardized. Further,
              the National Tariff Policy at clause No. 5.3(h)-4 has
              prescribed that uncontrollable costs should be recovered
              speedily to ensure that the future consumers are
WP(C) No. 4821/2010                                              Page 16 of 19
               not burdened with the past costs. It is felt that non-true-
              up of the account of the year 2009-2010 where quantum
              of uncontrollable costs were very high, would mean that
              future consumers would be burdened with the interest
              cost of the year 2009- 2010 which goes against the
              above quoted clause of National Tariff Policy.

              As the issues raised by the Distribution Companies as
              well as the issue of burdening future consumers with
              past liabilities are issues which are very serious in
              nature, the Government in exercise of its power under
              section 86(2)(iv) directs the DERC to give statutory
              advise and clarification to the Government on the issue
              raised by the Distribution companies in the enclosed
              representations as well as on the issues covered under
              clause 5.3(h)-4 of the National Tariff Policy. The
              Government further directs under section 108 of the
              Electricity Act, 2003 that the Delhi Electricity
              Regulatory Commission will not issue the tariff order
              till the statutory advice given by the Commission as
              asked for, is thoroughly examined by the Government
              and the Government gives a go ahead for passing of
              tariff orders."
                                                  [emphasis supplied]


21.    On a close scrutiny of the aforesaid directions, it is clear as noon day

that there has been an order of prohibition to the Commission not to pass

the tariff order. Mr. Dave, learned senior counsel for the respondent would

contend that it was issued keeping in view the public interest. The same is

not discernible.      It is neither evident nor demonstrable.       It was an

unwarranted interdiction. It is understandable that the State Government

could have suggested some kind of a matter relating to policy having nexus

with public interest, but unfortunately that is not so. By the impugned

communication contained in Annexure P-7, the State Government could

not have prevented the Commission from exercising its statutory powers.

In any event, under Section 108, the State Government could have only

WP(C) No. 4821/2010                                               Page 17 of 19
 issued policy direction, not pre-emptory directions, like it did.           As

submitted by the learned Attorney General for the Union of India, the

interpretations placed by the Apex Court on Section 78-A in the decisions

which we have quoted in extenso would clearly convey that the State

Government as well as the Board functions in different fields within the

statutory limits. Any encroachment is not permissible. The case at hand

projects that no iota of policy, any way, is discernible and the concept of

public interest appears to be a subterfuge, in fact, totally divorced from the

arena of public interest. Quite apart from that the communication is in the

form of injunction, which we are absolutely indubitable, the State

Government cannot issue. This interdiction is decidedly beyond the scope

of language employed in Section 108 of the 2003 Act and, in fact, contrary

to the legislative intent.    Thus, we are disposed to think that the

submissions canvassed by learned Attorney General deserve acceptation

and, accordingly, we hold that the communication of the present nature

made by the State Government is absolutely unjustified, unwarranted and

untenable and, accordingly, the same stands quashed.


22.    We will be failing in our duty if we do not mention that Mr. Salve,

learned senior counsel though had initially supported the order passed by

the State, yet later on conceded to the proponement canvassed by the

learned Attorney General for the Union of India.


23.    In view of our aforesaid analysis, the instruction given by the State

vide Annexure-P7 is quashed.

WP(C) No. 4821/2010                                             Page 18 of 19
 24.    The writ petition be listed on 23rd February, 2011 for hearing on

other issues before regular DB-1.


                                                 CHIEF JUSTICE



                                                 MANMOHAN, J.

FEBRUARY 18, 2011 Dk/pk WP(C) No. 4821/2010 Page 19 of 19