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Karnataka High Court

Karavalli Bus Owners Association (R) vs Union Of India on 2 June, 2025

Author: M.Nagaprasanna

Bench: M.Nagaprasanna

                           1



Reserved on   : 26.04.2025
Pronounced on : 02.06.2025                           R
       IN THE HIGH COURT OF KARNATAKA AT BENGALURU

           DATED THIS THE 02ND DAY OF JUNE, 2025

                          BEFORE

         THE HON'BLE MR. JUSTICE M. NAGAPRASANNA

          WRIT PETITION No.9159 OF 2025 (GM - RES)

BETWEEN:

1.   KARAVALI BUS OWNERS ASSOCIATION (R)
     REGISTERED UNDER
     KARNATAKA SOCIETIES ACT, 1960
     DATED 19.10.2020, UDUPI-MANGALORE
     SRI GANESH, LIONS MARG
     BRAHMAGIRI, UDUPI - 576 101
     REPRESENTED BY ITS PRESIDENT
     SRI K.RAGHAVENDRA BHAT
     S/O SUBRAMANYA BHAT
     AGED ABOUT 50 YEARS
     PROP: BHARATHI MOTORS
     LIONS MARG, BRAHMAGIRI
     UDUPI - 576 104.

2.   SMT. MANIMALLALA BALLAL
     W/O K.RAJAVARMA BALLAL
     AGED ABOUT 58 YEARS
     BUS OPERATOR, NO.1-10-2
     JAYARAJ HOLE BAIL, BIJAI
     MANGALORE - 571 004
     DAKSHINA KANNADA.
                             2



3.   SRI K.ANANTHAKRISHNA BHAT
     S/O SRINIVAS BHAT
     AGED ABOUT 55 YEARS
     NO.1-33-R, SREE VISHNU HOUSE
     MULLAGUDDE, PERDOOR POST
     UDUPI TALUK AND DISTRICT - 576 104

4.   SRI SUBHASH RAI
     S/O LATE K.B.JAGANNATH RAI
     AGED ABOUT 45 YEARS
     BUS OPERATOR
     NO.15-9-463/10, FLAT NO.104
     NEAR SAMRUDIYA APARTMENT
     GANESH GARDEN, KADRI
     MANGALORE - 570 004
     DAKSHINA KANNADA.

5.   MR. SHABEER NAWAB SAB
     S/O NAWAB SAB
     AGED ABOUT 48 YEARS
     NO.2111, DEVI NAGAR
     K.H. B.COLONY, KUNJATH BAIL
     MANGALORE - 575 101.

6.   IMTIYAZ AHMED
     S/O K.AHMED
     AGED ABOUT 40 YEARS
     NO.2-39(1), NEAR
     NEW PICCO COMPANY
     HULIYAR GOLI, UDUPI - 574 106.

7.   MRS. CHANDRIKA
     W/O M.S.VADIRAJ
     AGED ABOUT 42 YEARS
     NO.6-40, SRI DEVI PRASAD
     THOTTAM POST, VADABHANDESHWARA
     MALPE, KODUR, UDUPI - 576 101.
                             3




8.   SRI MOHAMMED ASHEER SAHEB
     S/O SRI K.SAHEB
     AGED ABOUT 48 YEARS
     BUS OPERATOR
     NO.5/26, NEAR OLD POLICE STATION
     MANUR VILLAGE AND POST, UDUPI
     UDUPI DISTRICT - 571 104.

9.   SRI MOHAMMED IMRAN
     S/O SRI UMMAR SAHEB
     AGED ABOUT 38 YEARS
     THUHEED MANZIL, MULOOR
     UDUPI TALUK AND DISTRICT - 576 104.

10 . SRI IDDINABERI SULAIMAN AHMED
     S/O SULAIMAN AHMED
     BUS OPERATOR
     AGED ABOUT 55 YEARS
     NO.4-112, BHASKAR NAGAR
     BADAGRAMA, UCHILA POST
     UDUPI DISTRICT - 576 104.

11 . SMT. KRISHNAKUMARI SHETTY
     W/O VIJAYKUMAR SHETTY
     AGED ABOUT 58 YEARS
     BUS OPERATOR
     NO.3-63(1), MAHAGIRI
     NEAR SANNABASAVANAKALLU
     GILIYAR, KOTA, UDUPI TALUK AND
     UDUPI DISTRICT - 576 104.

12 . SRI SATHISH
     S/O KRISHNA SHERUGAR
     AGED ABOUT 36 YEARS
     BUS OPERATOR, H.NO.2/121
     KOTE ROAD, KALYANPURA,
     TO-NST-EAST, SANTHEKATTE
                             4



    UDUPI - 576 104.

13 . SRI GANANATHA HEGDE
     S/O K.JAYACHANDRA HEGDE
     AGED ABOUT 45 YEARS
     BUS OPERATOR, NO.12-2-75
     PREETHAM, S.P. OFFICE ROAD
     BRAHMAGIRI, UDUPI - 576 101.

14 . SMT. SHASHI S.RAI
     W/O SUBHASH RAI
     AGED ABOUT 40 YEARS
     M/S. SUGAMA TOURIST
     MYTHRI COMPLEX
     SERVICE BUS STAND
     UDUPI - 576 101.

15 . SRI HARISH RAI
     S/O LATE K.B.JAGANNATH RAI
     AGED ABOUT 45 YEARS
     BUS OPERATOR, NO.3-W-32-2760/61
     JAIL ROAD, KODIYAL BAIL
     MANGALORE - 575 001
     DAKSHINA KANNADA.

16 . SRI K.JAYARAM SHETTY
     S/O LATE K.GOPAL SHETTY
     AGED ABOUT 43 YEARS
     BUS OPERATOR, NO.3-33-291
     1/8, FLAT NO.202, 2ND FLOOR
     MERCURY APARTMENT
     VIJAY CHURCH CROSS
     MANGALORE - 575 001
     DAKSHINA KANNADA.

17 . SRI NELSON PERIERA
     S/O DOMNIC PERIERA
     AGED ABOUT 52 YEARS
                           5



   NO.302, SILVER SPRINGS
   DOOR NO.17/7-433/11
   BEYOND BELAVAI APARTMENT N.R.,
   VALENTIA CIRCLE, FATHER MULLER ROAD
   MANGALORE - 575 001
   DAKSHINA KANNADA.

18 . SMT. SUJATHA V.SHETTY
     W/O VASANTHA SHETTY
     AGED ABOUT 45 YEARS
     BUS OPERATOR, NO.1-108
     MAHALAKSHMI
     OPP. DHARMAVARAM AUDITORIUM
     VARAMBALLI, DHARMAVARA
     UDUPI - 576 106.

19 . SRI KISHAN KUMAR HEGDE
     S/O K.R.HEGDE
     AGED ABOUT 52 YEARS
     NO.401, ZEN GARDEN, KITTUR
     CHANNAMMA ROAD, AJJARKADU
     UDUPI - 576 101.

20 . SMT. PRASADINI K.HEGDE
     W/O SRI KISHAN KUMAR HEGDE
     AGED ABOUT 50 YEARS
     NO.401, ZEN GARDEN, KITTUR
     CHANNAMMA ROAD, AJJARKADU
     UDUPI - 576 101.

21 . SMT. PREMALATHA N.SHETTY
     W/O SRI B.NARAYANA SHETTY
     AGED ABOUT 70 YEARS
     BUS OPERATOR
     SRI VIJAYALAXMI NIVAS
     KOTTARA CHOWKI, DEREBAIL
     MANGALORE - 575 005
     DAKSHINA KANNADA
                             6




22 . SRI SATHYARAJA SHETTY
     S/O SHASHIDHARA SHETTY
     AGED ABOUT 52 YEARS
     PROP: SUGAMA TOURIST
     MYTHRI COMPLEX
     NEAR SERVICE BUS STAND
     UDUPI - 576 101.

                                                 ... PETITIONERS

(BY SRI PUTTIGE R.RAMESH, SR. ADVOCATE A/W.,
    SRI A.S.PARASARA KUMAR, ADVOCATE)

AND:

1 . UNION OF INDIA
    BY THE SECRETARY TO THE GOVERNMENT
    MINISTRY OF ROAD TRANSPORT
    AND HIGHWAYS, NEW DELHI - 110 001.

2 . THE PROJECT DIRECTOR
    NATIONAL, HIGHWAYS AUTHORITY OF INDIA
    MINISTRY OF ROAD TRANSPORT
    AND HIGHWAYS, GOVT. OF INDIA
    PROJECT IMPLEMENTATION
    UNIT NO.3-29, BETHEL
    THARE THOTA, NEAR PUMPWELL (NH-66)
    MANGALORE - 575 002.

3 . M/S. UDUPI SASTHANA TOLLWAY PRIVATE
    LTD., HEJAMADI AND SASTHANA TOLL PLAZA
    HEJAMADI, UDUPI DISTRICT, UDUPI - 576 101.
    THE COMPANY REGISTERED UNDER
    COMPANIES ACT, 1956
    REPRESENTED BY MANAGER.

4 . THE DEPUTY COMMISSIONER AND
                               7



  DISTRICT MAGISTRATE
  NEAR A.B. SHETTY CIRCLE
  OPP. TO NEHRU MAIDAN
  MANGALORE
  DAKSHINA KANNADA - 575 001
  REPRESENTED BY ITS CHAIRMAN.

                                                 ... RESPONDENTS

(BY SRI ADITYA SINGH, CGC FOR R1;
    SMT. SHILPA SHAH, ADVOCATE FOR R2;
    SRI C.K.NANDAKUMAR, SR. ADVOCATE FOR
    SRI RAGHURAM CADAMBI, ADVOCATE FOR R3;
    SRI SHAMANTH NAIK, HCGP FOR R4)

     THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND
227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE
ORDER      PASSED        BY       THE      R-2       IN      NO.
11039/15/2025/PIU(MNGLR)/1332 DTD 1.02.2025 VIDE ANNX-L;
PROHIBIT THE R-3 NOT TO DEDUCT ANY ADDL TOLL CHARGES
AMOUNT FROM THE PETITIONERS FASTAG WALLET ACC OF THE
PETITIONERS AND COLLECT THE TOLL CHARGES ONLY AS PER THE
REGISTERED LADEN WEIGHT WHICH WEIGHTS BETWEEN 7,500 TO
12,000   KGS   ONLY   FROM    FASTAGE   WALLET    ACCOUNTS   OF
PETITIONERS VIDE ANNX-N, N1 TO N21.



     THIS WRIT PETITION HAVING BEEN HEARD AND RESERVED
FOR ORDERS ON 26.04.2025, COMING ON FOR PRONOUNCEMENT
THIS DAY, THE COURT MADE THE FOLLOWING:-
                                  8



CORAM:      THE HON'BLE MR JUSTICE M.NAGAPRASANNA

                             CAV ORDER


      The    1st   petitioner/Karavali    Bus    Owners   Association

(hereinafter referred to as 'the Association' for short) and other bus

operators of Mangalore and Udupi Districts are at the doors of this

Court calling in question an order dated 01-02-2025, by which the

representation of the Association comes to be rejected, confirming

debit adjustment charges made towards movement of buses of the

Association in the toll plazas. A consequential prohibition is sought

against the 3rd respondent not to deduct any additional toll charges

from FASTag wallet account of the petitioners.



      2. Sans details, facts in brief, are as follows:-


      The petitioners claim to be existing stage carriage permit

holders operating in Dakshina Kannada and Udupi Districts. The

grievance of the petitioners is that, the stage carriages operated by

them move through Hejamadi and Sastana toll plazas among

others. It is their allegation that, the fare that will be charged on

every trip of each vehicle should be taken into consideration on the
                                        9



laden weight of the vehicles, which is between 7,500 and 12,000

Kgs. insofar as mini vehicles are concerned. The further allegation

is that the aforesaid two toll plazas deduct from the FASTag wallet

of the petitioners on the vehicles passing through FASTag ID which

is linked to the FASTag account, when it is scanned at the toll

plazas. However, notwithstanding the said fee paid to enter the toll

plaza, the 3rd respondent - Udupi Sasthana Tollway Private Limited

without notice to the petitioners has been deducting additional toll

charges from the FASTag wallet account of all the stage carriage

permit holders of the Association. The petitioners come to know of

the fact of 3rd respondent withdrawing additional toll charges in the

form of "charge back process" from FASTag wallet account as and

when it wishes to do so.



      3.    The   Association     then       submits     a   representation   on

21-07-2024 about its grievance to the 4th respondent - Deputy

Commissioner and District Magistrate, Udupi District, alleging that

there is an illegal activity of collecting excessive toll charges from

the account of the petitioners when scanning the FASTag ID and

sought     to   stop   the   illegal       deductions.       In   response,   the
                                  10



representation comes to be rejected by the National Highways

Authority of India (hereinafter referred to as 'the NHAI' for short)

holding that in terms of the schedule appended to the concession

agreement, the debit adjustment followed as there is a mismatch

found.    It is challenging the said communication along with the

continued action of collection of toll fee allegedly twice, the

petitioners are at the doors of this Court.



        4. Heard Sri Puttige R.Ramesh, learned senior counsel

appearing for the petitioners; Sri Aditya Singh, learned Central

Government Counsel appearing for respondent No.1, Smt. Shilpa

Shah,     learned    counsel    appearing       for   respondent   No.2,

Sri   C.K.Nanda     Kumar,   learned   senior    counsel   appearing   for

respondent No.3 and Sri Shamanth Naik, learned High Court

Government Pleader appearing for respondent No.4.


SUBMISSIONS:

PETITIONERS:

        5. The learned senior counsel appearing for the petitioners

takes this Court through the Motor Vehicles Act, 1988 ('the Act' for
                               11



short) and places reliance upon several definition clauses to

contend that 'bus' no where in the Act is defined. Therefore, we

have to fallback upon the definition of 'vehicle' in the Act. The

transport authorities have classified vehicles on laden and unladen

weight. Vehicles which are about 12000 Kgs. are said to be busses

and which are below 12000 Kgs. are said to be minibuses.        He

would contend that the vehicles of the petitioners have all gross

vehicle weight of less than 12000 Kgs.   Therefore, those vehicles

cannot be categorized as buses. They are minibuses. According to

the concession agreement, minibus is 50% less than a bus.

Therefore, deduction in the toll plaza holding that there is a

mismatch between registration of vehicles and the capacity or what

is uploaded into the FASTag account, cannot be made. He would

further contend that the requirement under the FASTag is what is

projected by the vehicle owners is to be deducted. Taking cue from

the Act, he would contend that deductions under the National

Highways Act is impermissible. He would thus, seek a direction to

stop the dual demands made.
                                 12



RESPONDENT NO.3 - THE CONCESSIONAIRE:


      6. Per contra, the learned senior counsel Sri C.K.Nandakumar,

representing the 3rd respondent, is a concessionaire from the NHAI

under a concession agreement, which is now collecting toll charges

at the toll plazas would take this Court through certain provisions of

the NETC Interface Control Document (ICD)       (hereinafter referred

to as 'the Manual' for short), which controls FASTag. Taking the

Court through the said Manual, he would justify toll deductions.

According to him, the Violation Matching under Clause 4.3, Violation

Audit by Toll Plaza under Clause 4.6 and dispute handling that is

permitted, all of which form a part of the concession agreement. It

is his submission that every concessionaire should get into an

agreement with the NHAI as a separate agreement and toll charge

is deducted in terms of those agreements.        He would take this

Court through the registration certificate of one of the vehicles

owned by the petitioners.    The vehicle is registered as a bus and

seating capacity is shown as 38.      The same owner uploads the

documents on the FASTag. The owner of the vehicle describes it as

a minibus and reduces the seating capacity to 32. When the vehicle
                                13



pass through the toll plaza, the FASTag immediately deducts what

is found in the FASTag document. Later, when it is noticed that

there is a mismatch, further deduction is made. He would submit

that there can be no qualm about the deductions made. He would

submit that the entire fee collection is dealt with under separate

Rules and drawing of Motor Vehicles Act is neither here nor there.

He would therefore, seek dismissal of the petition.



RESPONDENT NO.1 - UNION OF INDIA;
RESPONDENT NO.2 - NATIONAL HIGHWAYS AUTHORITY OF
INDIA & RESPONDENT NO.4 - THE STATE GOVERNMENT:

      7. Learned counsel representing the respondents 1, 2 and 4

would also toe the lines of the learned senior counsel representing

the 3rd respondent, contending that the statute operates for

collection of fee, which is entirely different from the one that is

projected by the learned senior counsel for the petitioners.   They

would contend that no fault can be found with the action of the 3rd

respondent.    They would all, in unison, seek dismissal of the

petition.
                                  14



      8. I have given my anxious consideration to the submissions

made by the respective learned counsel and have perused the

material on record.



      9. The facts, as outlined, are not in dispute. The existence of

deductions is not denied.       The singular issue that beckons

adjudication    is,   whether    the   concessionaire        is   legally

empowered to effectuate, a second toll charge, post facto on

the premise of data mismatch?



      10. The consideration of the aforesaid issue, necessitates an

exploration of the governing statutory scheme - Motor Vehicles

Act, 1988 ('MV Act' for short); National Highways Act, 1956

('the Act' for short); the Rules framed thereunder, the

National    Highways     Fee     (Determination     of   Rates       and

Collection) Rules, 2008 ( 'the Rules' for short). It is apropos

to notice certain provisions of the afore-quoted statutes.
                                  15



MOTOR VEHICLES ACT, 1988:

      11. Section 2 of the Act deals with definitions. Certain

definitions are germane to be noticed.       Section 2(15) of the Act

deals with 'gross vehicle weight'; Section 2(17) deals with 'heavy

passenger vehicle'; Section 2(21) deals with 'light motor vehicle';

Section 2(24) deals with 'medium passenger motor vehicle'; Section

2(35) deals with 'public service vehicle'. Section 2(40) deals with

'stage carriage'; Section 2(47) deals with 'transport vehicle' and

Section 2(48) deals with 'unladen weight'. All the above definitions

read as follows:


             "2(15) "gross vehicle weight" means in respect of any
      vehicle the total weight of the vehicle and load certified and
      registered by the registering authority as permissible for that
      vehicle;
                          ....           ....           ....
             2(17) "heavy passenger motor vehicle" means
      any public service vehicle or private service vehicle or
      educational institution bus or omnibus the gross vehicle
      weight of any of which, or a motor car the unladen
      weight of which, exceeds 12,000 kilograms;
                          ....           ....           ....
             2(21) "light motor vehicle" means a transport
      vehicle or omnibus the gross vehicle weight of either of
      which or a motor car or tractor or road-roller the
      unladen weight of any of which, does not exceed
      7500 kilograms;
                          ....           ....           ....
             2(24) "medium passenger motor vehicle" means
      any public service vehicle or private service vehicle, or
      educational institution bus other than a motor
                                  16



     cycle, adapted vehicle, light motor vehicle or heavy
     passenger motor vehicle;

            2(35) "public service vehicle" means any motor vehicle
     used or adapted to be used for the carriage of passengers for
     hire or reward, and includes a maxi-cab, a motor-cab, contract
     carriage, and stage carriage;
                    ....           ....          ....
            2(40) "stage carriage" means a motor vehicle
     constructed or adapted to carry more than six
     passengers excluding the driver for hire or reward at
     separate fares paid by or for individual passengers,
     either for the whole journey or for stages of the
     journey;
                    ....           ....          ....
            2(47) "transport vehicle" means a public service vehicle,
     a goods carriage, an educational institution bus or a private
     service vehicle;

           2(48) "unladen weight" means the weight of a
     vehicle or trailer including all equipment ordinarily used
     with the vehicle or trailer when working, but excluding
     the weight of a driver or attendant; and where
     alternative parts or bodies are used the unladen weight
     of the vehicle means the weight of the vehicle with the
     heaviest such alternative part or body;"


                                            (Emphasis supplied)


A stage carriage as defined under Sub-section (40) of Section 2 of

the Act would mean a motor vehicle constructed or adapted to carry

more than six passengers inter alia the driver. A heavy passenger

motor vehicle as defined under Section 2(17) of the Act would

mean a public or a private service vehicle or a motor car of which

the unladen weight exceeds 12000 Kgs. The light motor vehicle as
                                17



defined under Section 2(21) of the Act could be a omnibus

transport vehicle whose unladen weight does not exceed 7500 Kgs.

Therefore, upto 7500 Kgs. is a light motor vehicle and beyond

12000 Kgs. is a heavy passenger motor vehicle. What happens

between 7500 and 12000 Kgs. is in the vacuum. The gross vehicle

weight as defined under Section 2(15) of the Act means weight in

respect of a vehicle and load certified and registered by the

registering authority as permissible. The medium passenger motor

vehicle as defined under Section 2(24) of the Act would be a light

motor vehicle, private or public. What is discernible from the afore-

quoted definitions is that, gross vehicle weight is what is found in

the certified and registered document of the registering authority.

Light and heavy motor vehicles are narrated hereinabove. The

medium passenger motor vehicle though defined, the weight of it is

left undefined. Transport vehicle is defined under Section 2(47) of

the Act, which would mean a public service vehicle or a private

service vehicle as the case would be.    The issue in the lis though

does not lead to interpretation of the afore-quoted provisions, they

become necessary to be noticed and considered and are, therefore,

afore-extracted.
                                18




NATIONAL HIGHWAYS ACT, 1956:


     12. The Act enables the Central Government to develop and

maintain National Highways and enter into concession agreements

for toll collection. Section 8A of the Act deals with power to enter

into concession agreements. It reads as follows:


           "8-A. Power of Central Government to enter into
     agreements for development and maintenance of
     national highways.--(1) Notwithstanding anything contained
     in this Act, the Central Government may enter into an
     agreement with any person in relation to the development and
     maintenance of the whole or any part of a national highway.

           (2) Notwithstanding anything contained in Section
     7, the person referred to in sub-section (1) is entitled to
     collect and retain fees at such rate, for services or
     benefits rendered by him as the Central Government
     may, by notification in the Official Gazette, specify
     having regard to the expenditure involved in building,
     maintenance, management and operation of the whole
     or part of such national highway, interest on the capital
     invested, reasonable return, the volume of traffic and
     the period of such agreement.

           (3) A person referred to in sub-section (1) shall
     have powers to regulate and control the traffic in
     accordance with the provisions contained in Chapter
     VIII of the Motor Vehicles Act, 1988 (59 of 1988) on the
     national highway forming subject-matter of such
     agreement, for proper management thereof."


                                         (Emphasis supplied)
                                   19



Section 8A empowers the Central Government to enter into

agreements     for    development      and   maintenance     of   national

highways. In furtherance of the development of the national

highways and in terms of Section 8A, the National Highway

Authorities have entered into concession agreement with the 3rd

respondent, who in terms of the agreement is empowered to deduct

fee for maintenance of roads. Section 9 of the Act empowers the

Government of India to frame Rules. Section 9 reads as follows:


            "9. Power to make rules.--(1) The Central Government
     may, by notification in the Official Gazette, make rules for
     carrying out the purposes of this Act.



            (2) In particular and without prejudice to the generality of
     the foregoing power, such rules may provide for all or any of the
     following matters, namely:--


             (a)     the manner in which, and the conditions
                     subject to which, any function in relation to
                     the development or maintenance of a national
                     highway or any part thereof may be exercised
                     by the State Government or any officer or
                     authority   subordinate   to   the    Central
                     Government or the State Government;

                     (aa) the manner in which the amount shall be
                     deposited with the competent authority under
                     sub-sections (1) and (6) of Section 3-H;
                                    20



            (b)    the rates at which fees for services rendered
                   in relation to the use of ferries, permanent
                   bridges, temporary bridges and tunnels on
                   any national highway 11[and the use of
                   sections of any national highway] may be
                   levied, and the manner in which such fees
                   shall be collected, under Section 7;

            (c)    the periodical inspection of national highways and
                   the submission of inspection reports to the Central
                   Government;

            (d)    the reports on works carried out on national
                   highways;

            (e)    any other matter for which provision should be
                   made under this Act.

              (3) Every rule made under this section shall be laid, as
      soon as may be after it is made, before each House of
      Parliament, while it is in session, for a total period of thirty days
      which may be comprised in one session or in two or more
      successive sessions and if, before the expiry of the session
      immediately following the session or the successive sessions
      aforesaid, both Houses agree in making any modification in the
      rule or both Houses agree that the rule should not be made, the
      rule shall thereafter have effect only in such modified form or be
      of no effect, as the case may be; so, however, that any such
      modification or annulment shall be without prejudice to the
      validity of anything previously done under that rule."


                                               (Emphasis supplied)


Invoking power under Section 9 of the Act, the Government of India

has framed Rules for the purpose of collection of toll.
                                  21



NATIONAL HIGHWAYS FEE (DETERMINATION OF RATES AND
COLLECTION) RULES, 2008:


      13. The preamble and certain provisions are germane to be

noticed. They read as follows:


              "In exercise of the powers conferred by section 9 of
      the National Highways Act, 1956 (48 of 1956) and in
      supersession of the National Highways (Temporary
      Bridges)     Rules,    1964,    the  National    Highways
      (Collection of Fees by any person for the Use of
      Section       of       National     Highways/Permanent
      Bridge/Temporary Bridge on National Highways)
      Rules, 1997, the National Highways (Fees for the Use
      of National Highways Section and Permanent Bridge-
      Public Funded Project) Rules, 1997 and the National
      Highways (Rate of Fees) Rules, 1997, except as respects
      things done or omitted to be done before such supersession,
      the Central Government hereby makes the following rules for
      collection of fee for use of sections of national highways,
      permanent bridges, by-passes and tunnels, namely:-"

                                            (Emphasis supplied)


Rule 2 deals with definitions.           Rule 2(d) defines who is a

'concessionaire'. It reads as follows:

            "Concessionaire" means a person with whom an
      agreement has been entered into under section 8-A of
      the Act;

                                            (Emphasis supplied)
                                  22



Rule 2(ga) deals with 'fee plaza'. It reads as follows:

           "fee plaza" means any building, structure or
      booth made for collection of fee;

                                            (Emphasis supplied)


Rule 2(ha), (hb), (hc) and (hd) deals with FASTag. It reads as

follows:

            "(ha) "FASTag" means an onboard unit
      (transponder) or any such device fitted on the front
      wind screen of the vehicles; and

            (hb) "FASTag lane of toll plaza" is an exclusive
      lane in the toll plaza for movement of vehicles fitted
      with "FASTag" or any such device.

             (hc) "Pre-paid payment instrument" means the
      instrument as defined by the Reserve Bank of India;
             (hd) "Electronic Toll Collection Infrastructure" means
      set of equipment comprising of hardware and software which
      shall facilitate electronic collection of user fees;


                                            (Emphasis supplied)

Rule 2(i) deals with 'gross vehicle weight' and reads as follows:

             "gross vehicle weight" in respect of any vehicle
      means the total weight of the vehicle and load
      certified and registered by the registering authority as
      permissible for that vehicle under the Motor Vehicles
      Act, 1988.


                                            (Emphasis supplied)
                                     23



A notification is issued amending certain provisions on 09.09.2024.

The amendment is to the following provisions:

           "G.S.R. 556(E). - In exercise of the powers conferred
     by section 9 of the National Highways Act, 1956 (48 of
     1956), the Central Government hereby makes the following
     rules further to amend the National Highways Fee
     (Determination of Rates and Collection) Rules, 2008,
     namely: -

     1.- (1) These rules may be called the National Highways Fee
     (Determination of Rates and Collection) Amendment Rules, 2024.

     (2) They shall come into force on the date of their publication in
     the Official Gazette.

     2. In the National Highways Fee (Determination of Rates and
     Collection) Rules, 2008 (hereinafter referred to as the said
     rules), in sub-rule (1) of rule 2,-

        (i) in clause (da) after the words "highway or
        expressway", the following shall be inserted,
        namely:-

           "and collected through Global Navigation Satellite
           System On-Board Unit or any such device or
           Automatic Number Plate Recognition Device or
           FASTag or any combination thereof";

        (ii) in clause (hd), after the words "user fees", the following
        shall be inserted, namely:-

           "through Global Navigation Satellite System On-Board Unit
           or Automatic Number Plate Recognition Device or FASTag
           or any combination thereof";

        (iii) after clause (hd), the following clause shall be inserted,
        namely:-

           "(he) "Global Navigation Satellite System On-Board Unit"
           means a non-transferable and firmly fitted device in a
           vehicle linked to Global Navigation Satellite System based
           user fee collection;';
                                     24



      3. In rule 6 of the said rules, in sub-rule (3), after the second
      proviso, the following proviso shall be inserted, namely:-

         "Provided also that exclusive lane can be earmarked for
         Global Navigation Satellite System On-Board Unit fitted
         vehicle and in case vehicle enters such lane, without a valid,
         functional Global Navigation Satellite System On-Board Unit,
         shall pay a fee equivalent to two times of the user fee
         applicable at that fee plaza:".

      4. In rule 9 of the said rules, after sub-rule (4), the following
      sub-rule shall be inserted, namely:-

         "(5) A driver, owner or person in-charge of a
         mechanical vehicle other than National Permit vehicle
         who makes use of the same section of national
         highway, permanent bridge, bypass or tunnel, as the
         case may be, shall be levied a zero-user fee upto
         twenty kilometers of joumey in each direction in a
         day under Global Navigation Satellite System based
         user fee collection system and if the distance
         travelled is more than twenty kilometers, then fee
         will be charged for actual distance travelled.".

                                        [F. No. 5016/01/2023-Toll]
                                   SUMAN PRASAD SINGH, Jt. Secy."


The notification amends the fee collection methodology, even to

bring global navigation satellite system for automatic number plate

recognition.   As   observed      hereinabove       Rule    2(d)   deals   with

concessionaire. The Government of India in the Ministry of Surface

Transport has entered into a concession agreement with the

concessionaire.     The concession agreement has a schedule to it,

which is Schedule-R.      Schedule-R is the same as schedule to the
                                   25



aforesaid Rules. In Schedule-R, base rate of fee is found. The base

rate of fee under Clause-4, of the Rules reads as follows:


      "4. Base rate of fee. - (1) The rate of fee for use of the
      section of national highway, permanent bridge, bypass or
      tunnel constructed through public funded project or private
      investment project shall be identical.

      (2) The rate of fee for use of a section of national highway of
      four or more lanes shall, for the base year 2007-08, be the
      product of the length of such section multiplied by the
      following rates, namely:-


            Type of Vehicle            Base rate of fee per km
                                       (in rupees)
       Car, Jeep, Van or Light                   0.65
       Motor Vehicle
       Light           Commercial                 1.05
       Vehicle,     Light    Goods
       Vehicle or Mini Bus
       Bus or Truck                               2.20
       Heavy            Construction              3.45
       Machinery (HCM) or Earth
       Moving Equipment (EME) or
       Multi Axle Vehicle (MAV)
       (three to six axles)
       Oversized Vehicles (seven                  4.20
       or more axles)


      Explanation.- For the purposes of this rule,-

         (a) "car" or "jeep" or "van" or "light motor vehicle"
         means any mechanical vehicle the gross vehicle weight of
         which does not exceed seven thousand five hundred
         kilograms or the registered passenger carrying capability
         as specified in the certificate of registration issued under
         the Motor Vehicles Act, 1988 does not exceed twelve
         excluding the driver;
                                 26




        (b) "light commercial vehicle" or "light goods
        vehicle" or "mini bus" means any mechanical
        vehicle with a gross vehicle weight exceeding seven
        thousand five hundred kilograms but less than
        twelve thousand kilograms or the registered
        passenger carrying capability as specified in the
        certificate of registration issued under the Motor
        Vehicles Act, 1988, exceeds twelve but does not
        exceed thirty two excluding the driver,

        (c) "truck" or "bus" means any mechanical vehicle
        with a gross vehicle weight exceeding twelve
        thousand kilograms but less than twenty thousand
        kilograms or the registered passenger carrying
        capability as specified in the certificate of
        registration issued under the Motor Vehicles Act,
        1988, exceeds thirty two, excluding the driver;

        (d) "heavy construction machinery" or "earth
        moving equipment" or "multi axle vehicle" means
        heavy construction machinery or earth moving equipment
        or mechanical vehicle including a multi axle vehicle with
        three to six axles or vehicle with a gross vehicle weight
        exceeding twenty thousand kilograms but less than sixty
        thousand kilogram; and

        (e) "oversized vehicle" means any mechanical vehicle
        having seven or more axles or vehicle with a gross vehicle
        weight exceeding sixty thousand kilograms."

                                           (Emphasis supplied)



For a light commercial vehicle, the base rate is Rs.1.05 per

km. and it is double for a bus or truck, which is at Rs.2.20

per km. The entire fulcrum of the lis lies in this.
                                  27




      14. The vehicles of the petitioners are registered by the

registering authority.   As an illustration, description of one of the

vehicles owned by the petitioners, is as follows:




Here the classification is a bus. The seating capacity is 38. But, the

unladen weight is 7300 Kgs. Another vehicle's description is as

follows:
                              28




This is also a bus, which weighs 11100 Kgs. and the seating

capacity is 38. What the members of the Association, would do is

upload the document on FASTag depicting, the vehicle to be a

minibus. The vehicle summary of one of the vehicles quoted

hereinabove is as follows:


     "Tag Account No.             34123978
     Licence Plate No.            KA20AB9797
      Vehicle Type                Mini Bus
     Status                       Active
     Black listed                 False
     Trip Code                    228"

                                           (Emphasis boxed)
                                  29



The vehicle description is minibus and the registration number is

the same as indicated hereinabove.        Therefore, the details of the

vehicle is uploaded by the owner, and the details of the vehicle are

drawn by the system from the Transport Department. Now, there

is undoubtedly a mismatch as the vehicle described by the

registering authority, as it is a bus and its seating capacity is 38.

The owner of the vehicle while uploading the details of the vehicle,

describes it as a minibus. If it is a minibus, it would become a

light motor vehicle and the fee would be Rs.1.05 per km. If it

is a bus, the fee would be Rs.2.20 per km. Therefore, the

difference is more than double. In this discrepancy, what the

concessionaire would do, or permitted to do, is found in the Manual.

Clauses 4.3 to 4.6 of the Manual read as follows:


     "4.3 Violation Matching:

        •   The toll plaza system receives Mapper Vehicle Class
            (MVC) in the response pay message and AVC input will
            be obtained from NETC lane.

        •   Any transaction where Mapper Vehicle Class is not
            equal to the Automated Vehicle Class (AVC) then such
            transactions are referred as violation transactions.

        •   The toll plaza auditor should validate the vehicle image
            and AVC profile for the violation transactions.
                             30



   •   If the violation is proved to be a valid violation
       after the audit then, the toll plaza can raise debit
       or credit adjustment with the Acquiring Bank. As
       per the process defined in violation audit
       section.

4.4 Blacklist Management (BL):

Online APIs are defined in the document to pull the
consolidated and incremental blacklist from the Acquiring
Host.

Incremental blacklist data should be used for updating the
toll plaza system and the consolidated blacklist should only
be used to match/ audit the net blacklist data in the toll
plaza system.


4.5 Log Standardization

Logs for all the operations performed at toll plaza must be
stored. These logs should be provided for audit and dispute
purpose. The plaza should maintain these logs for 3 years
and should be retrieve easily for future reference or dispute.
The sample format of log is attached for reference. The plaza
and acquirer bank can use format or any other standard
format applicable for their respective system.

4.6 Violation Audit by Toll Plaza

1. The Concessionaire system should raise the violation
through violation API only after verifying Mapper class
received Response Pay Message API with the AVC class for
the said transactions. If they observe any discrepancy in
MVC Vs AVC then only violation should be raised.

2. Toll plaza operator should upload minimum 2 and
maximum 5 images of vehicle for violation processing. This
should be automated process, whenever they are raising
violation images of those transactions should be stored on
SFTP. The size of the image should not be more that 2 MB.
                                   31



      3. The Acquirer Bank should provide the acknowledgment for
      all the successful images received to the toll plaza on SFTP.
      The acquirer bank and plaza should use the existing logic of
      ACK/NACK of toll file for images as well.

      4. Reference to the point number 4.2 File transfer of ICD 2.4
      CCH document, as per the existing process the Acquirer
      banks should create additional new folder in the name of
      'Image Ack Status' under the respective Concessionaire
      Outbound folder in the SFTP for sharing the status of Image
      acknowledgment      for   accepted  or     decline   violation
      transactions."

                                             (Emphasis supplied)


The Manual further permits the concessionaire of dispute handling.

The dispute handling as obtaining in Clause 17 of the Manual reads

as follows:


      "17 Dispute Handling


      17.1 Dispute Cycle Definitions

              The various disputes supported by Acquirer bank are
              defined as follows:

      17.2 Credit adjustment:

              Credit adjustment would be raised for reversing the
              excess funds received to the tag holder. It can be
              raised on settled transactions only.

      17.3 Debit adjustment:

              Debit adjustment would be raised for violation
              cases along with the valid proofs/ evidences for
                              32



       receiving the difference amount from tag holder.
       It can be raised on settled transactions only.


17.4 Chargeback:

       It is a message through which the issuer/tag
       holder demands a full or partial reversal of an
       amount earlier charged on NETC transactions. A
       chargeback is always accompanied by a reason
       and evidences due to which it is being
       demanded.


17.5    Chargeback     acceptance    /   Chargeback     deemed
       acceptance:

       It is notification message generated by the acquirer/
       toll plaza operator to indicate an acceptance of the
       chargeback raised by the issuer/tag holder.

17.6 Credit Chargeback:

       It is a message generated by issuer/ tag holder to
       raise a reversal (partial or full) of the NETC transaction
       to acquirer/ toll plaza operator.

17.7 Credit chargeback acceptance / Credit chargeback
     deemed acceptance:

       It is notification message generated by the acquirer/
       toll plaza operator to indicate an acceptance of the
       chargeback raised by the issuer/tag holder.

17.8 Re-Presentment:

       It is a message by which the acquirer bank/ toll plaza
       operator rejects the chargeback claimed by issuer/ tag
       holder with valid proof/ evidences.
                                 33



     17.9 Re-Presentment acceptance / Re presentment deemed
           acceptance:

           It is a message initiated by the issuer in consent with
           tag holder to indicate acceptance of the re-
           presentment message transmitted by the acquirer/ toll
           plaza operator.

     17.10 Good Faith:

           The good faith message would be generated by either
           of the party i.e. Issuer/ tag holder or by Acquirer
           bank/ toll plaza operator for the transactions where
           dispute TAT is expired. It is the last cycle of dispute
           handling where the dispute is settled with mutual
           consent from both the parties.

     17.11Good faith acceptance:

           This message is generated by a receiving party to
           indicate its acceptance of a good faith case raised by
           initiating party. Good faith acceptance can be
           full/partial.

     17.12 Good faith declined/ Good Faith deemed declined:

           This message is generated by a receiving party to
           indicate that it rejects the good faith case concerning
           it raised by initiating party."

                                           (Emphasis supplied)


The Start to Stop of chargeback flow chart as obtaining under

Clause 17.13 of the Manual, is as follows:
                              34




The dispute reason codes under Clause 18 of the Manual, reads as

follows:
                                35



     "18 Dispute Reason Codes

        Dispute can be raised by the Toll plaza operator
        based on the following reason defined by NPCI.

     18.1 Debit Adjustment


     Reason Code             Description
     1001                    Toll fare calculation error
     1002                    Vehicle class mismatch
     1003                    Unregistered Tag in the mapper
     1004                    Vehicle is not in exempted list
     1005                    Vehicle is not in black list
     1006                    Vehicle is not in low balance list
     1007                    Other Specify


     18.2 Credit Adjustment

     Reason Code             Description
     2001                    Toll fare calculation error
     2002                    duplicate transaction done at Toll
                             Plaza
     2003                    Tag     holder    was    charged for
                             unsuccessful transaction
     2005                    Paid by other means
     2006                    Vehicle is in exempted list
     2007                    Other Specify"


                                               (Emphasis boxed)


Clauses 4.3 and 4.6 supra permit the toll plaza system to notice

violation matching and enter into violation auditing. Under Clause

17, which deals with dispute handling, the concessionaire is

empowered to credit adjust, debit adjust and charge back. The
                                 36



debit adjustment can be for several reasons. One of the reasons is,

vehicle class mismatch. Same goes with the charge back.



      15. What is discernible from the afore-quoted clauses is that

the concessionaire is entitled to do a debit adjustment in case of a

vehicle mismatch. In the case at hand, the vehicle mismatch has

arisen on the variation with the registration certificate issued by the

Regional Transport Authority which is found in the records of the

Department and what is uploaded on to the FASHag. The

registration shows the vehicle of the members of the petitioner as a

bus and what is uploaded on to the FASHag is a mini bus. This is

ostensibly taking cue from the vacuum that is in the Motor Vehicles

Act where heavy motor vehicle and light motor vehicle qua their

laden weight is defined. The definition 'bus' is nowhere found. The

vehicles of the petitioners do weigh 12000 kgs. If it is less than

12000 kgs., in terms of the Act it can be neither described as a light

motor vehicle nor a heavy motor vehicle. In the light of the

statutory vacuum as to what happens to vehicles weighing 7500

kgs. to 12000 kgs. it appears, the Association seeks clarification

from the hands of the Transport Authority. The Transport Authority
                                             37



clarifies in the following manner. The Transport Department clarified

it on 10-02-2025. It reads as follows:

                                        " ಂ ಬರ ಹ

                ಷಯ: ಾಹನದ ವಗ ಕು ತು ಸ ಕರಣ ಕು ತು.

               ಉ ೇಖ:    !ೕ."ಾಘ ೇಂದ! ಭ%, ಅಧ()ರು, ಕ"ಾವ* ಬ+ ,ಾ-ೕಕರ ಸಂಘ,
                        ಉಡು/ gÀªÀgÀ Cfð ¢£ÁAPÀ: 10.02.2025
                                          ****
               0ೕ-ನ ಉ ೇಖದ-ಯ         ಷಯ1ೆ2 ಸಂಬಂ34ದಂ5ೆ, 6ೕ7ಾರು       ಾಹನಗಳ 1ಾ9:
     1988 ರ ಪ!1ಾರ ಈ 1ೆಳ=ನಂ5ೆ          ಾಹನದ ತೂಕವನು? ಆಧ 4 ಪ!AಾBಕರ           ಾಹನಗಳ
     ವಗ ವನು? CಗDಪEಸ ಾ=ರುತFGೆ.

      ಕ!.ಸಂ
      ಕ! ಸಂ.
         ಸಂ       ಾಹನದ ತೂಕ (H
                            H ೋ Iಾ!ಂ)
                                  Iಾ!ಂ - PÉf                    ಾಹನದ ವಗ
         1       7500 ರವ"ೆIೆ                                     LPV
        2        7501 jAzÀ 12000 gÀªÀgÉUÉ                        MPV
        3        12001 ನಂತರದ ಾಹನಗ*Iೆ                             HPV
        4        AಾವJGೇ RLW ಇದ:ರೂ Stage Carriage              ಾಹನಗ*Iೆ BUS ಎಂದು
                 ನಮೂGಾ=ರುತFGೆ.
                           Gೆ
                          Gೆ


                                                                 ¸À»/-
                                                        Oಾ!Gೇ ಕ Pಾ Iೆ ಅ31ಾ ,
                                                             ಉಡು/ Q ೆ ಉಡು/."

                                                     (Emphasis added)


The description of vehicle from 7501 to 12000 Kgs. is said to be a

medium passenger vehicle and whichever vehicle of laden weight as

aforesaid, is described as a bus. This endorsement has generated

certain obfuscation. The obfuscation is owing to the provisions of
                                  38



the Act. Fee collection is not dealt with under the Act. It is dealt

with under the aforesaid Rules framed under the Highways Act.

Schedule-R therein to the Rules is the same, which is found in the

Manual / concession agreement quoted hereinabove. Schedule-R

clearly defines the collection to the passenger capacity. If the

submission of the learned senior counsel is to be accepted, it would

lead to huge losses to any person for the reason that the

Association is wanting to take advantage of the vacuum under the

Act. Notwithstanding the registration of the vehicles as buses, the

vehicle owners describe their vehicles as minibuses and, for

illustrations when they were to pay ₹1,000/- as toll fee, they will

pay ₹500/-, notwithstanding the description, of it as a bus.

Therefore, we have to fallback upon the Highways Act and the

Rules, and the agreement between NHAI and the concessionaire.



      16. The dispute mismatch is noticed and therefore, the fee in

terms of registration certificate is collected. It is not the submission

of the learned senior counsel for the petitioners that fee beyond the

fee prescribed for a bus is collected. It is his submission that these

vehicles though registered as buses, they cannot be treated as
                                   39



buses at all, for the collection of toll fee. The said submission is

unacceptable. This was a representation made by the petitioners to

the third respondent on 01.02.2025, in the form of an appeal, to

get   chargeback   process    stopped.    The   representation    of   the

Association reads as follows:-

                                                 "Date 01-02-2025

      To,

            M/s Udupi Tollway Private Limited
            Hejamadi Toll Plaza
            Hejamadi, Udupi Dist
            Udupi, Karnataka


      Subject: Protest at Sasthana and Hejamdy toll plaza
      against illegal withdrawal of money from FASTag
      wallet account without notice.

      I would like to bring to your kind attention about the illegal
      activity of withdrawing the money from the FASTag wallet
      account without notice.

      According to the norms, a FASTag account is created
      for all buses. When the bus passes the toll plaza,
      according to BHARATH KA RAJPATRA, THE GAZETTE OF
      INDIA, the money will be withdrawn from the FASTag
      wallet account after scanning the FASTag ID at toll
      plaza, which is accepted.

      There is difference in the criterion sub-clauses
      4.(2).(b) and 4.(2).(c) of the schedule-R-Fee
      Notification of the Concession Agreement of NHAI and
      the criteria for categorizing the vehicle for issuance of
      FASTags mentioned under "FASTAG ISSUANCE,
      VEHICLE CLASSIFICATION DOCUMENT", which is
                             40



leading to the aggravation by the Karavali Bus Owners
Association®.

In order to compensate this, continuously money is
withdrawn from the account while the bus is not at toll
plaza or without scanning the FASTag ID. This
continued till the account balance shows negative.

After repetitive requests and complaints regarding the same
matter, against the Hejamadi and Sasthana Toll Plaza
manager, your highness (the project director) has referred
the above matter to the competent Authority of NHAI. The
matter is still under examination. But on 29th January 2025,
without any order from NHAI, your highness has given the
instructions to the Sasthana and Hejamadi Toll plaza to start
deducting the money from the wallet as "CHARGE BACK
PROCESS", which is illegal and against the low and justice.
The deduction has started from wallet as additional charges
(chargeback) without any direction from the Competent
Authority.

To protest this unlawful activity at toll plaza, all bus owners,
drivers and conductors have decided to conduct a silent
strike at Hejamadi and Sasthana toll plaza on 5th February
2025.

Thank you for your attention to this matter. We look forward
for your favorable response by stopping this cheating activity
and take appropriate action against the manager at
Hajamadi and Sasthana Toll Plaza and grant justice.


Thanks and regards:


Raghavendra Bhat
President
Karavali Bus Owners Association
Udupi/Mangalore.

Jithendra Jain
Secretary
Dilraj Alva
                                41



     Honorary President."
                                              (Emphasis added)


This comes to be rejected by an endorsement dated 01-02-2025,

which reads as follows:


     "To,

     The President

     Karavali Bus Owners Association
     Udupi/Mangalore
     Lions Marga, Bhramagiri,
     Udupi - 576101

     Sub: Four laning of Kundapur - Surathkal Section (Km
     283.300 to km 358.080) (Section-1) Mangalore to Kerala
     Border (i.e. Nantoor Circle to Mahaveer Circle) to Kerala
     Border (km 3.7 to km 17.200) (Section-2) Of NH-66 (Old
     NH-17) in the State of Karnataka on DBFOT Basis under
     NHDP-III (Package No. KAR/Phase-III/IC/2010) - Collection
     of User Fee based on the Classification of "Light
     commercial Vehicle" or "Light Goods vehicle" Or "Mini
     Bus" - Reg.

     Ref: Karavali Bus Owners Association (R) Letter no. NIL
     dated 21.07.2024


     Sir,

           This has reference to the above letter dated
     21.07.2024 wherein it was requested to stop the deduction
     of additional charges through FASTag at Hejamadi and
     Sasthan Toll Plazas.


           The project from Kundapur-Surathkal was taken up on
     PPP (DBFOT mode) and the Concession Agreement for the
                                42



above project was executed on 09.03.2010. And the Fee
Notification as per the existing Fee Rules at the time of
executing forms a part of the Concession Agreement.

       The sub-clauses 4. (2). (b) and 4. (2). (c) of the
'Schedule-R - Fee Notification' of the Concession Agreement
& User Fee Gazette notification S.O.623(E) dated 12.03.2013
states the following:

   (b) "light commercial vehicle or "light goods vehicle" or
   "minibus" means any mechanical vehicle with a gross vehicle
   weight exceeding seven thousand five hundred kilograms but
   less than twelve thousand kilograms or registered passenger
   carrying capability as specified in the certificate of registration
   issued under the Motor Vehicles Act, 1988, exceeds twelve but
   does not exceed thirty-two excluding the driver...

   (c) "truck" or "bus" means any mechanical vehicle with a
   gross vehicle weight exceeding twelve thousand kilograms but
   less than twenty thousand kilograms or registered passenger
   carrying capability as specified in the certificate of registration
   issued under the Motor Vehicles Act, 1988, exceeds thirty-two
   excluding the driver...

In view of the above, largely there are two parameters based
on which the Registration Certificate is being issued to the
respective class of vehicles. The first parameter is the Gross
Vehicle Weight and the second parameter is the seating
capacity based on the goods vehicle or the passenger
vehicle.

      Although the Gross Vehicle Weight of the vehicle
is less than twelve thousand kilograms, the RTO has
been issuing the Registration Certificates to the
vehicles by tagging them as "Bus"; considering the
seating capacity rather than the gross vehicle weight
since it has a passenger carrying capability of more
than thirty-two excluding the driver based on the
stipulations made in the Motor Vehicles Act, 1988.
Accordingly, any passenger carrying vehicle that has a
seat capacity above thirty-two seats excluding driver
tagged as "Bus" by RTO shall be charged under the
"Bus or Truck" category defined in the 'Schedule-R -
Fee Notification' of the Concession Agreement and the
                                    43



        Concessionaire raised the debit adjustment if any
        mismatch is found.

              However, the FASTags are issued by the various
        FASTag issuance agencies based on the Gross Vehicle
        Weight (GVW), however the Concessionaire is
        following the chargeback mechanism based on the
        number of passengers, as per the provisions of
        Schedule-R of the Concession Agreement,

              In view of the above, the Concessionaire has
        followed the provisions of the Concession Agreement
        in line with the User Fee Gazette notification
        S.O.623(E) dated 12.03.2013 is collecting the user fee
        based on the passenger capacity.

             This is for your information please.


                                            Yours faithfully,
                                                  Sd/-
                                          (Abdulla Javed Azmi)
                                        DGM(T) & Project Director,
                                         NHAI, PIU-Mangalore."


                                                (Emphasis added)


What is narrated hereinabove is, what is answered to the

petitioners. The concessionaires rejection of the representation

made by the petitioners on 01-02-2025 is thus found to be lawful,

justifiable and within the four corners of the governing legal frame

work.    The debit adjustment or the charge back mechanism has

been    rightly   invoked   in   view    of   the   discrepancies    between

registration data and the uploaded FASTag information.
                                    44



      17. What is discernible from the preceding analysis is,

while the Motor Vehicles Act defines classes of vehicles for

regulatory purposes, toll classification is governed solely by

the   National      Highways      Act,    the    Fee    Rules    and    the

Concessionaire agreement.               The legal foundation for toll

adjustments due to vehicle mismatch is both statutory and

contractual,     making   the      petitioners'        grievance   legally

untenable.     Thus, finding the petition devoid of merit, it would

necessarily meet its dismissal.



      18.   Before    parting     with     the    order,   it   would   be

appropriate    to    observe      that    the    legislative    framework

especially the Motor Vehicles Act, 1988 calls for a re-

examination qua description of vehicles. The Union Ministry

of Surface Transport, the 1st respondent, would do well to

undertake a review and insert appropriate clarificatory

definitions, to address the evolving complexities of vehicular

classifications and toll collection. The present dispute, while

resolved within the existing legal rubric, reveals the need for

statutory refinement.
                                    45




        19. In the light of the preceding analysis, the following:


                                  ORDER

(i) The Writ Petition being devoid of merit stands dismissed.

(ii) The 1st respondent shall endeavour to redefine the classes of vehicles in the Motor Vehicles Act, 1988, bearing in mind the observations made in the course of the order, failing which, it would result in mushrooming of such submissions being projected.

(ii) Copy of this order shall be furnished to the Additional Solicitor General of India.

Sd/-

(M.NAGAPRASANNA) JUDGE nvj CT:SS