FL-2 Liquor Licence Restrictions for Private Clubs Are Distinct From TASMAC Shop Location Rules

The petitioner, a resident of Dindigul, filed a Writ of Certiorarified Mandamus to quash the order dated 28.01.2026 passed by the 2nd Respondent (Commissioner of Prohibition and Excise) granting an FL-2 liquor licence to the 3rd Respondent, Honeybee Recreation Club.

The petitioner alleged the Club was located within 100 metres of a National Highway and close to hospitals, temples, a vegetable market, and educational institutions.

The 1st Respondent (District Collector) filed a counter-affidavit stating the Club is 205 metres from the National Highway, 63 metres from a Co-operative Management Institution, and that the "temple" mentioned was actually a Samadhi (not a place of worship).

1. Whether the grant of an FL-2 licence to the 3rd Respondent violated statutory distance restrictions or guidelines regarding proximity to educational institutions, places of worship, or National Highways.

2. Whether the restrictions applicable to TASMAC retail shops (FL-1) under the Tamil Nadu Liquor Retail Vending Rules, 2003, extend to non-proprietary clubs holding FL-2 licences.

Tamil Nadu Liquor (License and Permit) Rules, 1981, specifically the conditions for Form F.L.2, which governs the possession and supply of liquor by non-proprietary clubs to their members.

G.O.Ms.No.32, Home, Prohibition Excise (VI) Department, dated 21.05.2018, issued pursuant to Supreme Court directions in M.A.Nos.489-491/2018 in Civil Appeal Nos. 12164-12166 of 2016, which prohibits liquor premises in close proximity to National Highways.

The Court distinguished these from the Tamil Nadu Liquor Retail Vending (In Shops and Bars) Rules, 2003, which apply specific distance restrictions to TASMAC retail outlets.

The Court noted that FL-2 licences are restricted to the supply of liquor within the confinement of the club to its members only.

Examining the factual findings in the District Collector’s counter-affidavit, the Court found that the 3rd Respondent’s premises are 205 metres away from the National Highway, thereby complying with the guidelines in G.O.Ms.No.32.

The Court accepted the Respondent’s contention that the alleged place of worship was a Samadhi and thus did not trigger the restrictions applicable to temples.

It further observed that the State had examined all criteria before granting the licence and that the petitioner’s apprehensions of rule violations were not founded on facts.

The Court dismissed the challenge to the licence but disposed of the writ petition with a direction to the 2nd Respondent to conduct periodic inspections to ensure the 3rd Respondent adheres to FL-2 licence conditions, specifically ensuring no sales are made to non-members or outside the premises. No costs were awarded.