Background: the petitioner approached the Chhattisgarh High Court under Article 226 alleging large-scale GST and Income Tax evasion by certain private entities. He claimed to have supplied documentary material, including invoices, weighbridge slips, affidavits and transaction records, to the GST authorities and sought a fair, impartial and time-bound investigation, recovery of any tax dues, and judicial supervision of the proceedings. The GST authorities had already initiated enquiries and issued summons to persons connected with the alleged transactions.
Issue: The principal issue before the Court was whether a person having no personal or legal interest in the alleged tax evasion could maintain a Public Interest Litigation seeking directions to GST and Income Tax authorities to investigate alleged tax evasion, disclose the progress of investigation, and recover the alleged statutory dues. The Court also considered whether its writ jurisdiction could be used to supervise or direct the manner in which statutory tax authorities conduct their investigation.
Court’s Decision: The Division Bench of the High Court of Chhattisgarh, comprising Chief Justice Ramesh Sinha and Justice Ravindra Kumar Agrawal, dismissed the PIL at the threshold. The Court held that the alleged tax liability involved disputed commercial transactions whose examination fell within the statutory domain of GST and Income Tax authorities. Since enquiries had already been initiated and summons issued, there was no demonstrated failure of statutory duty or mala fide action warranting judicial intervention. The Court further held that merely describing the petition as a PIL could not convert a dispute concerning identified private parties and their tax liability into genuine public interest litigation. The petitioner had also previously filed a substantially similar writ petition, which was dismissed for lack of locus standi. Consequently, the Court found the present PIL misconceived and impermissible, dismissed it, and ordered forfeiture of the security amount deposited by the petitioner. Santosh Agrawal (Goyal) v. Union of India & Ors., WPPIL No. 45/2026, decided on 7 August 2026, High Court of Chhattisgarh at Bilaspur.