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Issues: Validity of compounding fee under GOMS No. 54 - Violation of Motor Vehicles Act, 1988 and Article 14 of the Constitution
In this judgment, the Supreme Court considered a special leave petition arising from a decision of the Andhra Pradesh High Court regarding the validity of GOMS No. 54, which increased the compounding fee for certain violations under the Motor Vehicles Act, 1988. The petitioners, owners of goods motor vehicles, challenged the validity of the fee hike as violative of the Act and arbitrary under Article 14 of the Constitution. The High Court upheld the GOMS, leading to the appeal before the Supreme Court. The Court examined Section 194 of the Motor Vehicles Act, which provides penal sanctions for driving violations and empowers officers to compound offenses under Section 200. The petitioners argued that the discretion given to prescribe compounding fees under Section 200 was unguided and arbitrary until a conviction under Section 194. They contended that specifying maximum rates for compounding was illegal and violative of Article 14. However, the Court disagreed, stating that Section 194 provides guidance to the State Government to specify compounding amounts, and the discretion to compound offenses is conditional upon the accused's willingness. The Court emphasized that the compounding fee should not exceed the fine prescribed by the penal section. Ultimately, the Court held that the Government, as a delegate, did not exceed its power in prescribing the compounding fee under Section 200 for offenses under Section 194. Therefore, the special leave petition was dismissed, affirming the validity of the compounding fee under GOMS No. 54 and upholding the decision of the Andhra Pradesh High Court.
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