A same-day hearing notice that affords no meaningful opportunity violates natural justice.

The petitioner challenged four orders in Form GST DRC-07, all dated 27 March 2026, concerning assessment years 2020–21 to 2023–24.

The personal hearing had been fixed for 24 March 2026 at 11:30 a.m. Although the notice was sent by RPAD on 20 March, the petitioner received it only on the scheduled hearing date and did not attend; the orders were thereafter passed without a personal hearing.

The petitioner confined its submissions to the denial of a hearing and stated it was willing to pay 5% of the disputed tax in each petition as a condition for remand. The respondent’s counsel acknowledged that no personal hearing had been provided.

1. Whether the impugned orders, passed without a personal hearing after the notice was received on the hearing date, violated the principles of natural justice.

2. Whether the impugned orders should be set aside and the matters remanded subject to the petitioner paying 5% of the disputed tax in each petition.

The Court applied the principle of natural justice that a party must be afforded a meaningful opportunity to be heard before an adverse order is passed.

A hearing notice received on the date fixed for the hearing, leaving the recipient unable to attend, did not provide that opportunity in the circumstances of this case. The judgment cites no specific statute or precedent as the basis for this rule.

The petitioner received the hearing notice only on 24 March 2026, the very date on which the hearing was scheduled, and was therefore unable to appear. The respondent admitted that no personal hearing was provided before the orders were made.

The Court held that, in these circumstances, the orders were passed in violation of natural justice and were not sustainable in law. Given the petitioner’s offer to pay 5% of the disputed tax, the Court made payment a condition of setting aside the orders and remanding the matters.

The petitioner must file its reply or objections and supporting documents within three weeks after payment. The respondent must then issue 14 days’ clear notice fixing a personal hearing and pass fresh orders on the merits and in accordance with law after hearing the petitioner.

The writ petitions were disposed of without costs, and the connected miscellaneous petitions were closed.