Authorities must treat the Section 80 CPC notice as a representation and decide it by a reasoned order after verification.

The petitioner, proprietor of M/s. Alankar Beej Bhandar, claimed that, pursuant to orders issued by the respondent Forest Department authorities, he supplied nursery seeds to the Forest Range Officer, Kawardha, during the period 2021–2023.

He submitted the corresponding bills, but alleged that outstanding payments amounting to ₹16,38,045 remained unpaid despite repeated requests.

The petitioner served a notice under Section 80 of the Code of Civil Procedure, 1908 (“CPC”) upon the authorities on 29 June 2026 and thereafter filed the present writ petition seeking payment with 18% interest, compensation, and other reliefs.

The State submitted that the Section 80 CPC notice could be treated as a representation and that the competent authority would examine and decide the claim after verifying the alleged supplies and records.

Whether the petitioner’s notice under Section 80 CPC could be treated as a representation requiring consideration and decision by the competent authorities.

Whether the Court should directly direct payment of the claimed amount of ₹16,38,045 with interest, or remit the matter to the authorities for verification and a reasoned decision.

The Court applied the procedural requirement under Section 80 of the CPC concerning notice before instituting proceedings against the Government or a public officer.

The Court further applied the principle that disputed claims involving verification of supplies, bills, and official records should initially be examined by the competent administrative authorities.

Where the Court remits such a representation, the authorities must undertake due verification, pass a reasoned order in accordance with law, and comply within the time prescribed by the Court.

The petitioner’s claim depended upon verification of whether the alleged nursery seeds were supplied pursuant to valid orders, whether the supplies were received and accepted, and whether the bills were duly payable.

Since these factual matters required examination of departmental records, the Court declined to adjudicate the payment claim directly.

Accepting the State’s submission, it treated the Section 80 CPC notice as a representation and remitted it to the concerned authorities for consideration in accordance with law.

In view of the petitioner’s assertion that the supplies dated from 2021 to 2023 and that considerable time had elapsed, the Court imposed a 60-day period for completion of verification and issuance of a reasoned order.

The Court expressly preserved the merits of the petitioner’s claim for determination by the authorities.

The respondent authorities were directed to treat the petitioner’s Section 80 CPC notice as a representation, verify the relevant records and supply-related claims, and pass a reasoned order within 60 days from receipt of a certified copy of the order.

The Court did not direct immediate payment, award interest or compensation, or express any opinion on the petitioner’s entitlement.