Writ jurisdiction against a show-cause notice is premature unless issued wholly without jurisdiction or legality.

The petitioner applied for a Retail Outlet dealership with Hindustan Petroleum Corporation Ltd. (HPCL) following a 2023 advertisement for a location "Within Majgaon village, Barpeta"

After a Draw of Lots and successful Field Verification of Credentials (FVC), the petitioner was issued a Letter of Intent (LoI) on January 30, 2024, and subsequently executed a Dealership Agreement on July 31, 2025, after investing approximately ₹70–80 Lakhs

On January 12, 2026, HPCL issued a Show-Cause Notice (SCN) alleging that the petitioner’s land was situated in Village Pota, Bajali District, rather than the advertised "Village Majgaon, Barpeta District"

The petitioner contended that the villages are contiguous, share revenue boundaries, and were affected by the administrative bifurcation of Barpeta into Bajali District

The petitioner challenged the SCN under Article 226, arguing it was impermissible after the execution of the Dealership Agreement and noting that the underlying complaint was not provided

1. Whether a writ petition under Article 226 of the Constitution is maintainable against a mere Show-Cause Notice before a final administrative decision is rendered

2. Whether the petitioner is entitled to the copy of the complaint that formed the basis of the Show-Cause Notice to ensure procedural fairness

The court primarily relied on the principle that writ jurisdiction under Article 226 is discretionary and should not ordinarily be exercised to quash a show-cause notice, as such notices do not infringe on rights until a final adverse order is passed

This doctrine was supported by Union of India v. Kunisetty Satyanarayana (2006), which held that a show-cause notice is premature and does not give rise to a cause of action unless issued without jurisdiction

Union of India v. Vicco Laboratories (2007), which emphasized that parties must first satisfy the authorities during the administrative process

The court reasoned that the issuance of the SCN is a tentative step towards a final decision and does not constitute a crystallized determination of rights

It observed that the petitioner has the opportunity to show sufficient cause to the respondent Corporation, which may lead to the proceedings being dropped

While the petitioner raised substantive grounds regarding the geographical contiguity of the villages and the prior approval by the Land Evaluation Committee, the court declined to comment on the merits to avoid causing prejudice to the pending administrative inquiry

However, the court identified a procedural gap, noting that for the petitioner to effectively exercise his right to reply, he must be privy to the specific allegations in the underlying complaint

Consequently, the court balanced judicial restraint regarding SCNs with the requirements of natural justice

It held that while the writ was premature regarding the merits of the SCN, the respondent must supply a copy of the complaint to the petitioner within seven days via email

The petitioner was granted 15 days from the receipt of the complaint to file a detailed representation and was permitted to request a personal hearing

Critically, the court ordered that no coercive action be taken against the petitioner in terms of the Show-Cause Notice until the respondent Corporation passes and communicates a reasoned final decision