Aggrieved parties must pursue statutory remedies under the PDR Act before invoking writ jurisdiction.

The petitioner, a food-processing industry, challenged orders passed by the District Certificate Officer, Banka, in Certificate Case No. 27 of 2014–15.

By order dated 28 January 2017, the petitioner’s liability was assessed at ₹3,47,12,973, although the original requisition was stated to be for ₹2,54,79,286.

By a subsequent order dated 15 May 2018, the petitioner’s objection was rejected, the petitioner was directed to deposit the amended amount with interest, and a warrant of arrest was directed to be issued.

The petitioner sought quashing of both orders and restraint against coercive recovery proceedings.

The respondents relied on the Supreme Court’s decision in Pawapuri Rice Mills v. Bihar State Food and Civil Supplies Corporation Ltd., 2024 SCC OnLine SC 3777, and the subsequent decision of the Patna High Court in Ranjeet Kumar Jha v. State of Bihar.

Whether the High Court should exercise its writ jurisdiction to examine the petitioner’s challenges concerning alleged procedural defects, defective notice, non-compliance with the Bihar and Orissa Public Demands Recovery Act, 1914 (“PDR Act”), and the validity of the certificate proceedings when a statutory remedy is available under the Act?

Whether the petitioner should be permitted to pursue the statutory remedy against the certificate proceedings, notwithstanding delay, and whether coercive steps should remain stayed during the prescribed period?

The Court applied the Bihar and Orissa Public Demands Recovery Act, 1914, particularly its statutory mechanism for objecting to and challenging certificate proceedings, including Section 9, as well as the appellate, revisional, review, and civil-court remedies referred to in Pawapuri Rice Mills.

The Court relied on Pawapuri Rice Mills v. Bihar State Food and Civil Supplies Corporation Ltd., 2024 SCC OnLine SC 3777, which held that the PDR Act is a comprehensive code providing safeguards and statutory remedies, and that parties ordinarily should exhaust those remedies before invoking writ jurisdiction, especially where the challenge involves disputed facts or alleged procedural irregularities.

The Court also followed Ranjeet Kumar Jha v. State of Bihar, C.W.J.C. No. 10379 of 2018, order dated 11 August 2026, which applied the same principle.

The petitioner’s objections concerned the validity of the certificate proceedings, including alleged defects in Form No. 1, non-compliance with prescribed procedure, absence of proper enquiry, and whether the amount was recoverable as a public demand.

These matters involved procedural and potentially disputed questions that could be examined by the competent statutory authority under the PDR Act.

Applying Pawapuri Rice Mills, the Court held that it should not adjudicate those issues directly in writ jurisdiction when an efficacious statutory remedy was available.

The Court therefore left the merits and all rival contentions open for consideration by the appropriate authority and granted the petitioner time to pursue the statutory remedy.

The petitioner was directed to avail the statutory remedy under the PDR Act before the appropriate authority within four weeks from receipt of the judgment.

Any delay in filing the appeal or statutory proceeding was directed to be condoned, and the competent authority was directed to dispose of the matter within three months from filing.

No coercive steps were to be taken against the petitioner in connection with the certificate proceeding during that period, subject to the petitioner availing the statutory remedy within four weeks.

All questions on merits were left open.