W.P.(C) Nos.23186 of 2022 & connected cases The batch writ petitions challenge Government Order GO(MS) No.121/2022/G.Edn dated 07/07/2022, which reduces the management quota in Private Aided Higher Secondary Schools to 20% and provides a 10% community quota for the students of the community to which the management belongs, with a rider that if the management does not declare its community, those 10% seats convert to merit seats under CAP. The petitioners, private aided school managers, argue that the policy infringes Articles 14 and 15 of the Constitution by creating an impermissible community-based reservation and that 30% management quota historically enjoyed by many schools is a vested right that cannot be withdrawn by executive policy. They also contend that the prospectus and CAP process must reflect merit, transparency, and non-discrimination. The State counters that the policy is a valid reform to cure long-standing anomalies, promote merit, and bring uniformity across government and aided institutions, and that the CAP system ensures merit-based admission. The High Court, while upholding the reduction of management quota to 20%, strikes down the 10% community quota as unconstitutional, holding it arbitrary and violative of Articles 14-15. It directs that the 10% seats be treated as open merit seats to be allotted through CAP, affirms the 20% management quota, and disposes of the petitions.
R.C.Rev. No.17 of 2023 arises from an eviction order under Section 11(2)(b) of the Kerala Buildings (Lease and Rent Control) Act, 1965, passed in RCP No.178 of 2015 by the Rent Control Court, Ernakulam, against Ragini Venugopal (the tenant). The Rent Control Appellate Authority, in RCA No.31 of 2022, concurred with a common judgment, sustaining eviction. While the appeal was pending, Ragini deposited arrears amounting to Rs.73,040 (April 2015–November 2018) though the initial rent due for the period was Rs.1,660 per month. The petitioner sought relief under Section 11(2)(c) to vacate the eviction order; the Rent Control Court dismissed I.A.1 of 2022, taking the view that the directives in prior orders, including a 2020 revision, remained binding. The Appellate Authority dismissed the appeal, interpreting the review order as not altering her statutory remedy under 11(2)(c). The petitioner challenged the entire course through a revision petition. The High Court, relying on Chinnamma v. Gopalan (SC) (1995) and noting that the deposit of arrears can ground relief under 11(2)(c), allowed the revision petition, held that the application under 11(2)(c) warranted fresh consideration, and directed the Rent Control Court to adjudicate I.A.1 of 2022 afresh, while staying any execution."
This High Court of Kerala, in a Civil Revision Petition, decides two closely linked issues arising from a public trust scheme filed under Section 92(1) CPC. The revisionists (Sreenarayana Vidya Mandir Trust and M. Ramakrishnan) challenge an order of the District Judge, Palakkad, granting leave to file suits under Section 92(1) CPC in OP (Leave) No.23/2021. The petitioners contend that there is an arbitration clause in the trust deed (Clause 20) and the dispute should be referred to arbitration, especially given mis-management allegations and demands for accountability. Relying on the Supreme Court’s Vinay Kishor Shah line of authority, they urge that trust disputes are not arbitrable even where an arbitration clause exists. The court, however, clarifies that the core issue is whether the reliefs sought fall within the in rem or in personam ambit and whether the disputes are arbitrable under Vidya Drolia’s four-fold test. It traces the public-trust framework (Madappa, Harnam Singh, Sugra Bibi, Vidyodaya Trust, Valia Koonambaikulam Temple) to determine the contours of Section 92 leave and concludes the plaint discloses grounds under 92(1)(b), (d), and (h). The District Judge’s leave order is upheld; the revision is dismissed. The court also directs expedited handling of urgent petitions within a month.
The appellant, Pradeepkumar K.G., challenged the Motor Accidents Claims Tribunal, Kottayam, award in OP(MV)439/2009 dated 24 February 2012. The accident occurred on 11 September 2008 when the auto-rickshaw in which the petitioner was traveling was hit by a car driven by the fifth respondent, resulting in injuries. The tribunal held the respondents liable (including the insurer) and awarded Rs.1,59,435 with interest and costs, on the basis of the available evidence, Exts A3–A7. The Insurance Company defended non-liability citing that the accident occurred due to the car driver’s negligence and that the auto-rickshaw driver lacked a licence and policy conditions were violated. The petitioner claimed higher notional income (and thus higher damages) and challenged the quantum under various heads, including loss of earnings and permanent disability. The State Supreme Court precedents cited (Ramachandrappa, Syed Sadiq, Pushkar Mehra) guided the court on notional income. The High Court, while upholding liability, re-evaluated the notional income, fixed at Rs.7,500 per month, and assessed permanent disability at 2%. It recalculated heads: loss of earnings Rs.22,500; permanent disability Rs.25,400; pain and suffering Rs.40,000. Overall award increased from Rs.1,59,435 to Rs.2,02,895, with a further enhancement of Rs.43,460 at 7.5% interest, payable within two months. The insurer may recover the enhanced amount from the first respondent after deposit before the Tribunal.
This is a writ petition under Article 226/227 challenging two orders: Exhibit P1 (dated 08-12-2014) issued under section 406(3) of the Kerala Municipality Act, 1994 by the Secretary of Kottayam Municipality, and Exhibit P2 (11-03-2016) in Appeal No.1398/14 of the Tribunal for Local Self Government Institutions, Thiruvananthapuram. The petitioner and his wife own 4.11 acres of property in Sy.No.99/1, Nattakam Village, along with an old shed. The challenge arises from alleged unauthorised construction: changing the roof and a wall, and installing two rolling shutters, which the Municipality and the Tribunal treated as unauthorised development requiring demolition. The petitioner contends that these works are not constructions requiring a permit, relying on Rule 10 of the Kerala Municipality Building Rules, 1999, which exempts certain works (including petty repairs and interior decoration) from building permits, and on E. Ansarudeen v. Tribunal for Local Self Government Institutions, Thiruvananthapuram (2013) 2 KHC 130, which held that replacing doors where none existed does not require a permit. The court considers whether changing wooden doors to rolling shutters and roof repairs amount to alterations requiring permits under Rule 2(f) and Rule 10 and under Ss. 366 and 386 of the Act. It ultimately allows the writ petition, quashing the challenged orders, while clarifying that potential nuisance claims may be pursued in civil proceedings and tenancy disputes remain to be resolved separately.
WP(C) NO. 39747 OF 2022; WP(C) NO. 40442 OF 2022; WP(C) NO. 42473 OF 2022 The writ petitions—WP(C) Nos. 39747/2022, 40442/2022 and 42473/2022—arise from separate awards issued under the Kerala Cooperative Societies Act against the petitioners for defaults on loans from the Njeezoor Service Co-operative Bank. The petitioners (husband and wife in 39747/2022 and 40442/2022; Sreeja P.V. in 42473/2022) challenge the ex parte awards, seeking setting aside on grounds of lack of opportunity to present a defence and due process. They prayed that the 2nd respondent (Arbitration and Execution General Office) be directed to consider their applications for setting aside the ex parte awards after hearing and that execution of the awards be kept in abeyance pending disposal of those applications. The bank contends that the awards were passed in 2018 and that the petitioners have shown no bonafide basis to stall payment. The court cites Rema Devi and others v. Joint Registrar of (General) Co-operative Societies (2016) 3 KHC 645 to emphasize fair consideration of such applications. Ultimately, the court disposes of the petitions by directing the 2nd respondent to hear and decide within two months, and to suspend further recovery if the petitioners deposit 25% of adjudicated amounts within one month, with such deposits to be adjusted against the liability. The petitions’ exhibits include the awards (Exhs. P1–P3) and applications to set aside.
This is a Kerala High Court criminal revision petition by the 2nd accused, Saneer, challenging the trial court’s discharge order dated 31.10.2023 in SC No.1012 of 2019 before the Additional Sessions Judge-V, Kollam. The SC No.1012 of 2019 relates to offences under Sections 212, 302, 307, 308, 323 and 324 read with Section 34 IPC, arising from an incident on 29.01.2015 near TKM Centenary Public School, Karikode, in which the 1st accused stabbed two witnesses and a bystander died, with the 2nd accused alleged to have harboured the 1st accused. The petitioner argues that the materials against him are too feeble to frame a charge under Section 212 IPC and relied on decisions like Union of India v. Prafulla Kumar Samal, Vijayan P., and Pradeesh Chacko, contending that the evidence does not meet the grave-suspicion standard. The Public Prosecutor contends that the statements of witnesses 9 and 21 demonstrate grave suspicion and that the petitioner assisted in sheltering and aiding the accused to evade punishment, including taking him to Changanassery. The High Court reviews the cited authorities and concludes the materials, if believed, connect the petitioner to harbouring and assisting the accused. The petition is dismissed, upholding the lower court’s view and leaving the discharge denial intact. The order ultimately directs that the accused face trial on the asserted charges.
This writ appeal (WA No.1730 of 2023) challenges the order of the Kerala High Court dismissing a petition that sought to stall recovery actions under the SARFAESI Act, initiated after default on a cash-credit facility of Rs. 10 lakh and subsequent enhancements. The appellant contends that the MSME Development Act, 2006 (MSMED Act) and the Framework for Revival of Micro, Small and Medium Enterprises mandate a protective, promotion-oriented regime, requiring stress identification and resolution mechanisms before recovery actions and asserting that no recovery under SARFAESI, RDB Act, or IBC would lie against a micro enterprise. It also claims compensation for alleged wilful breach of trust, misrepresentation in Ext.P3, and seeks writs to quash SARFAESI actions, restrain classifications as NPA or wilful defaulter, and require a committee under Ext.P8 to grant reliefs mandated to the enterprise. The High Court, in a judgment dated 22/08/2023, rejected these contentions. On appeal, this Division Bench upholds the impugned order, clarifying that MSMED Act rights accrue only upon proper registration (Section 8, Udyam) and that the Framework’s procedures are mandatory. It distinguishes Kotak Mahindra Bank Ltd v. Girnar Corrugators but relies on Transcore and Kunhayammed for procedural principles and merger of review with appeal. Ultimately, the writ appeal is dismissed, as the bank’s actions were not shown to have violated the applicable mandatory procedures.
This Criminal Misc. Case (CRL.MC No. 9105/2023) from the Kerala High Court challenges the Magistrate’s dismissal of an application to send two cheques for expert opinion in ST No.1120/2019 under Section 138 NI Act. The petitioner, P. Bindu, contends she merely handed over two blank cheques and took photocopies before giving them to the complainant; the complaint alleges that the cheques were signed, filled, and dishonoured for insufficient funds. The petitioner sought to send the cheques to an expert to verify whether the signatures on the cheques fully superimpose with the signatures on the photocopies and to determine whether the amounts/writings were added later. The Magistrate rejected the request on the ground that photostat copies cannot be sent for expert opinion unless the originals are produced with contemporaneous documents. The High Court agrees that the photostat copies can be used as secondary evidence under Section 65(a) of the Indian Evidence Act, particularly since the originals are already marked, and directs the lower court to recall the petitioner and mark the photocopies. It also allows a possible comparison under Section 73 if relevant, and directs expeditious disposal of the case. The court acknowledges Bir Sing v. Mukesh Kumar to the extent that a signed blank cheque may be filled and still be valid, but emphasizes the defence evidence cannot be foreclosed.
V. Vijayakumar, complainant in CMP 1043/2022 before the Judicial First Class Magistrate Court, Chavakkad, challenged an order that had declined to register an FIR and had directed the enquiry to be conducted under Chapter XV of the Cr.P.C. The complainant alleged obstruction by the second respondent, who is the Station House Officer of Guruvayur Temple Police Station, and alleged criminal intimidation as well as threats of false implication to deter him from pursuing the complaint. The Magistrate had previously forwarded the complaint under Sec. 156(3) Cr.P.C. for investigation, but subsequently, by Annexure-8, opted to proceed under Chapter XV, expressing concern that a fair investigation could not be expected if the matter were remanded for police action under Sec. 156(3). The court noted that the accused is a police officer and cited the Supreme Court’s decision in CBI v. State of Rajasthan (AIR 2001 SC 668) to emphasize that magisterial power under 156(3) Cr.P.C. cannot be stretched beyond directing the officer in charge of the police station to conduct the investigation. It also referred to a Supreme Court observation in S.L.P. (Crl) No. 9062/2022 urging adjudication on merits without undue influence from High Court observations. The Kerala High Court decided there was no merit in the Crl.M.C., affirmed the Magistrate’s approach, and dismissed the petition; it held that a fair investigation could be pursued under Chapter XV and Section 200 Cr.P.C. Accordingly, the order was upheld and interference refused.
Cont. Appeal(C) No.9 of 2023 This Contempt Appeal (Cont. Appeal(C) No.9 of 2023) before the Kerala High Court arises from W.P.(C) No. 3711 of 2023 and the accompanying Cont. Case No. 1630 of 2023. The appellant, Suresh K, challenges Annexure A1, a judgment dated 21.08.2023 of the learned Single Judge that closed the contempt proceedings on the strength of a memo filed by the Special Government Pleader. The memo purportedly records compliance with directions from the judgment dated 22.05.2023 in W.P.(C) No. 3711 of 2023, directing the Land Revenue Commissioner to reconsider the matter and redress the petitioner’s grievance, after affording an opportunity of hearing. The appellant contends that the alleged compliance is inadequate because the document on record is only a communication dated 09.08.2023 from the Land Revenue Commissioner to the District Collector, and no personal hearing was afforded. The bench examines Section 19(1)(a) of the Contempt of Courts Act, 1971 read with Section 5 of the Kerala High Court Act, 1958, and surveys several precedents on the scope of contempt jurisdiction and its appealability. It relies on Anil Kumar T.R. v. Premkumar V.R and V.M. Manohar Prasad v. N. Ratnam Raju to explain that only an order punishing contempt is appealable under Section 19, with exceptions for intra-court challenging routes. The court ultimately holds Annexure A1 as not appealable under Section 19(1)(a) or Section 5, and dismisses the Contempt Appeal as not maintainable, while noting the appellant may seek reopening before the Single Judge.
This suo motu Division Bench petition (DBP No.114 of 2023) before the Kerala High Court concerns a devotee’s complaint about flex boards installed near the Koodalmanikyam Temple and requests for renovation of temple structures. Registered on the basis of a complaint dated 26.09.2023 by Pradeepkumar, the matter progressed as the Municipality indicated removal of a flex board on 12.11.2023 and the Devaswom body sought time for instructions; by 20.11.2023 there was no flex board on the front public road. The court heard the Senior Government Pleader for the State, the Standing Counsel for Koodalmanikyam Devaswom Managing Committee (respondents 2 and 3), and the Standing Counsel for Irinjalakkuda Municipality. The judgment cites the Koodalmanikyam Devaswom Act, 2005, particularly Sections 3 (vesting of administration in the Managing Committee), 10 (duties for rites, worship facilities, safe custody of funds, order and hygiene, and expenditure control), and Section 20 with Schedule 1 of the Act (1971) to support the governance framework. It also references constitutional and statutory authorities on public road rights and worshipper rights (C.S.S. Motor Service v. Madras State; Saghir Ahmad; Sodan Singh; and Suo Motu decisions), among others, to underscore the need to prevent encroachments and protect pedestrian mobility. The court notes pendency of WP(C) No.9586 of 2023 regarding temple repairs. The DBP is disposed with directions at paragraph 12, requiring the 4th respondent to ensure no flex boards and no encroachment on the right of way, and to address temple repairs.
This Criminal Miscellaneous Case challenges an order under Section 482 CrPC quashing CC No.200/2013, arising from Crime No.1009/2012 of Kadakkavoor Police Station, Thiruvananthapuram. The petitioners, Sabu and Ramz, were accused of offences under Sections 323 and 324 read with 34 IPC. They seek quashing on the ground that the parties have settled their dispute and do not wish to continue the prosecution. The victims support the settlement, whereas the Public Prosecutor expresses reservations about quashing solely on the basis of settlement. The court considers Supreme Court guidance on quashing non-compoundable offences, particularly State of Madhya Pradesh v Laxmi Narayan and Others (2019 (5) SCC 688), which permits quashing where the dispute is private/civil in nature and settled, while excluding heinous offences or offences under special statutes. The High Court notes that Laxmi Narayan relied on Gian Singh v. State of Punjab and Narinder Singh and Others v. State of Punjab, and sets out factors such as the nature and severity of the offence, injuries, and antecedents. Applying these principles, the court finds the dispute private and the settlement genuine, and allows the Crl.M.C, quashing all further proceedings against the petitioners in CC No.200/2013.
CRL. M.C. No. 7891 of 2023 This Kerala High Court criminal miscellaneous case under Section 482 CrPC concerns nine accused in SC No.461/2023 arising from Nadapuram Police Station Crime No.113/2015, charged with offences including sections 143, 147, 148, 452, 427, 436, 395, 227 and 506(ii) read with 149 IPC for alleged dacoity. The petitioners seek to quash the ongoing prosecution on the ground that the parties have settled their dispute and do not wish to pursue the case. The victims have filed affidavits indicating consent to quashing. The Public Prosecutor initially expresses reservations about quashing solely on the basis of a settlement but concedes that the matter is settled. The court reviews the record and relies on Supreme Court authority in Laxmi Narayan, Gian Singh and Narinder Singh to articulate the principle that under Section 482 CrPC, quashing is permissible for non compoundable offences when the dispute is private, the parties have settled the entire dispute, and the offences do not involve serious public interest or heinous nature. The court enumerates the governing considerations including whether the offences are private in nature, the conduct of accused, and the presence of an overall civil character to the dispute. Applying these factors, the court finds the dispute private and the settlement acceptable, and accordingly allows the criminal miscellaneous case and quashes the proceedings against the petitioners in SC No.461/2023.
CRL.M.C. NO. 8836 OF 2023 This Kerala High Court Criminal Miscellaneous Case under Section 482 CrPC arises from CC 1100/2019 of the Judicial First Class Magistrate Court-II, Kollam, in which the petitioner Ramesh M (3rd accused) is charged with offences under Sections 394, 450, 506 read with 34 IPC arising from Crime No.156/2019 of Sakthikulangara Police Station. The prosecution alleges that the accused, while committing robbery, inflicted hurt and committed related offences. The petitioner contends that the dispute between the parties has been settled and that the victim has supported quashing via an affidavit. The Public Prosecutor initially expressed reservations about quashing based solely on settlement but conceded the matter is settled. The court surveys Supreme Court authority, notably State of Madhya Pradesh v. Laxmi Narayan and Others (2019) 5 SCC 688, along with Gian Singh v. State of Punjab and Narinder Singh and Others v. State of Punjab and Another, to frame the law on exercise of the power under Section 482 CrPC. The court reiterates that quashing non‑compoundable offences may be permissible in private disputes where the civil character predominates and the entire dispute is resolved, while not applying to heinous offences or offences under special statutes. After examining the facts and records, the court holds the dispute private, settlement accepted, and accordingly allows the Criminal Miscellaneous Case, quashing all further proceedings against the petitioner in CC 1100/2019.
This Regular First Appeal (R.F.A. No.356/2022) arises from a suit for specific performance of a sale agreement concerning land in Kurichikkara Village, Thrissur. On 6 May 2010, the defendant agreed to sell 3 acres 84.5 cents of land to the plaintiff for a substantial sum, with earnest money paid and the balance to be paid and registered by certain dates. The parties extended the agreement multiple times, the last extension being on 23 February 2011, with the understanding that if the resurvey issue was not resolved by 7 March 2011, the agreement would not be extended further and the undisputed land would be registered by 10 March 2011. The total payments reportedly amounted to Rs.45 lakhs. The plaintiff sent a lawyer’s notice demanding specific performance; the defendant resisted, claiming the contract was rescinded by mutual agreement and that Rs.45 lakhs should be refunded with interest. The Trial Court awarded specific performance for the entire plaint schedule property but excluded 39.03 cents due to surveying disputes. On appeal, issues include whether the non-examination of the plaintiff is fatal, and whether time was of the essence. The court cites Man Kaur and Citadel Fine Pharmaceuticals to discuss who should testify and to interpret time-related defenses. It ultimately holds that the plaintiff remained ready and willing, dismisses the appeal, and upholds the trial court’s decree for specific performance with exception of the disputed 39.03 cents.
This is a writ petition under Article 226 challenging government orders related to the exemption from test qualifications for a promoted principal of an aided higher secondary school. The petitioner, P.V. Sujathan, who was promoted as Principal of the P.R. Memorial Higher Secondary School, Panoor, contends that because he attained 50 years of age at the time of promotion (01.06.2016), he should be exempt from the test qualification under Rule 13B of KS & SSR (Part II). He argues that there is no specific provision in Chapter XXXII KER governing exemption for test qualification in the Kerala Education Rules, so mutatis mutandis application of Rule 13B to KS & SSR should extend the exemption to aided principals as well, mirroring the exemption already granted to Government Higher Secondary School principals and other heads. The petitioner asserts that the classification creating a disparity between aided and government institutions is irrational, given identical duties, control, pay, and supervision under the same department. Ext.P10 denying the exemption is alleged to be discriminatory and arbitrary, and Ext.P5/Ext.P10 are targeted for quashing. The government’s position, argued by the respondents, is that Rule 9 of Chapter XXXII KER governs aided school teachers and that Rule 13B does not automatically apply to aided schools. The court disposes of the petition by setting aside Ext.P10 and directing reconsideration by the first respondent, within three months, after taking into account the contentions raised in para 11 of the writ petition. The judgment emphasizes equal treatment for similarly situated posts while preserving the government’s power to decide on reconsideration.
This Criminal Miscellaneous Case (CRL.M.C. 9051 of 2023) under Section 482 of the Code of Criminal Procedure, 1973, arises from CP 48/2021 before the Judicial Magistrate of First Class-III, Punalur, connected to Crime No.312/2018 of Pathanapuram Police Station, Kollam. The petition seeks to quash the ongoing prosecution for offences under IPC sections 143, 147, 148, 341, 294(b), 323, 324 and 308 r/w 149. The accused contend the dispute has been resolved via settlement, supported by affidavits from victims who express no objection to quashing. The State Public Prosecutor (respondent) initially resists quashing solely on the basis of a settlement but concedes that the matter is settled. The court carefully examines the records, including victim affidavits, and cites binding Supreme Court authority (State of Madhya Pradesh v. Laxmi Narayan and Others) to outline the exceptional scope of Section 482 CrPC to quash non-compoundable offences where the dispute is private and resolved, while excluding heinous offences and offences under special statutes from quashing. It also notes that the High Court may assess whether charges like Section 307 IPC are implicated, based on evidence whether the charge is intended or actually supported by evidence. The High Court deems the dispute private in nature and accepts the settlement, thus allowing the petition and quashing all further proceedings in CP 48/2021 arising from Crime 312/2018, with the order pronounced by Justice P.V. Kunhikrishnan.
This is a criminal appeal under Section 383 Cr.P.C. by the appellant Alex, S/o Anthony, challenging a conviction for murder under Section 302 read with Section 34 IPC and the life sentence imposed by the Sessions Court, Thrissur, in SC No.110/2011. The prosecution alleged that on 21 March 2010, at about 7:15 pm, Alex and his associates assaulted Suresh, resulting in his death; the motive cited is animosity and alleged misconduct by the accused. The trial court convicted both accused (the present appellant and co-accused Sanoop) and sentenced them to life imprisonment with a fine, allowing set-off for custody. The High Court, in this jail appeal, re-examines the evidence: ocular witnesses PW1 and PW2, the inquest and postmortem reports (Exts.P2, P3, P9), chemical analysis (Ext.P10) showing alcohol, seizure of MO1 knife, and the FIS of CW1. The court considers whether death was homicidal, whether the causal connection from the accused to the death is established, and whether the accused could be guilty of murder under Section 300 IPC. It also analyzes the admissibility and weight of FIS under Section 47 and the evidentiary rules of Section 60, including expert treatises. The court finds the death to be homicidal, caused by injury No.14, and that the accused acted in concert, dismissing the appeal and upholding the conviction. Bench: Alexander Thomas, J. and C.S. Sudha, J.
These writ appeals arise from two separate assessments for the year 2017-18 under the CGST and SGST Acts, where the purchasing dealers were denied input tax credit due to a mismatch between their GSTR-2A and GSTR-3B returns. The appellants—Nahasshuko or Nahasshukoore (M/S N.S. Metals) and Ansil Ibrahim (M/S Light House)—challenged the orders and the constitutional validity of Section 16(2)(c) CGST Act and Rule 36(4) CGST Rules. The High Court held that input tax credit is a concession, not a fundamental right, and can be availed only if conditions in the statute are satisfied, including possession of a tax invoice or debit note, receipt of goods or services, payment of tax, and timely filing of returns. The burden is on the dealer under Section 155 to prove eligibility, and the appellants failed to produce tax invoices and to exhaust remedies; the court dismissed their petitions. While considering the constitutional arguments, the bench rejected the claim that the challenged provisions discriminated under Article 14 or were manifestly arbitrary, noting that the credit is a conditional concession and that the State may regulate it via criteria for eligibility. The court referenced authorities such as ALD Automotive, Godrej, and the manifest-arbitrariness standard. Consequently, both writ appeals were dismissed, though without prejudice to challenging the assessments within due process of law.