Writ Court Cannot Adjudicate Claims Involving Materially Disputed Factual Questions Requiring Evidence.

The petitioner, a small-scale industry, filed three writ petitions claiming unpaid dues for materials supplied under the MGNREGA scheme to various Development Blocks in Darrang District, Assam

In WP(C) 5296/2020, the petitioner claimed an outstanding amount of ₹9,74,625/-; in WP(C) 5388/2023 (sic 2020), ₹8,32,183/-; and in WP(C) 5453/2020, ₹3,71,129/-.

The Panchayat and Rural Development (P) Department filed an affidavit-in-opposition categorically denying the claims, stating that upon verification, no such material bills were found in the Management Information System (MIS).

Despite being granted time, the petitioner failed to file an affidavit-in-reply to contest these factual denials.

1. Whether the High Court, in its writ jurisdiction, can adjudicate on the recovery of dues when there is a categorical factual denial regarding the supply and existence of outstanding bills

2. Whether the petitioner is entitled to the benefit of Section 14 of the Limitation Act for the period spent pursuing these writ petitions

The Court applied the established principle that writ jurisdiction under Article 226 of the Constitution of India is not the appropriate forum for resolving "disputed questions of facts" that require detailed factual adjudication and evidence.

The Court also applied Section 14 of the Limitation Act, 1963, which allows for the exclusion of time spent bona fide in a court without jurisdiction or a forum unable to entertain the matter due to a defect of jurisdiction or other cause of a like nature.

The Court observed that while the petitioner asserted the supply of materials and subsequent non-payment, the respondents filed a common affidavit-in-opposition explicitly stating that no such bills appeared in the mandatory MIS system.

The Court held that it could not decide whether the supply was actually made or whether payments remained outstanding solely based on the writ record, as such matters require the leading of evidence in a proper trial.

Since the petitioner failed to file a reply to the state's denial for over nine months, the disputed nature of the facts was reinforced.

Consequently, the Court found the high-level summary procedure of a writ petition unsuitable for resolving these specific monetary claims.

The Court granted the petitioner liberty to approach a competent Civil Court for relief and directed that the petitioner is entitled to the benefit of Section 14 of the Limitation Act, 1963, excluding the period from 03.12.2020 until the date of this judgment for future civil suit computations.