2023 (11) TMI 686 - SCH - Service Tax

Specific relief or universal relief - HELD THAT - The relief specifically granted by the Division Bench is limited to those who are parties before the Court - Further clarification made by the Division Bench is that it was not making a universal declaration in respect of all institutions in whatever manner they are being conducted. Again, the Court has reiterated that the declaration granted under the impugned judgments will apply to the parties to the appeals who are the petitioners in the Writ Petitions and the Department is free to examine the cases of the parties who are not before the Court independently in accordance with law. Appeal dismissed.

Summary

Issues involved: Interpretation of relief granted by Division Bench, scope of declaration, liberty to consider cases independently.

Interpretation of Relief Granted: The Supreme Court examined the relief specifically granted by the Division Bench, emphasizing its limitation to parties before the Court. The Court reiterated that the relief did not extend to a universal declaration for all institutions, highlighting the specificity of the granted relief to the parties involved in the appeals. The Division Bench clarified that the declaration applied only to petitioners in the Writ Petitions, allowing the Department to independently assess cases of parties not before the Court. Consequently, the Supreme Court declined to interfere with the impugned judgments, affirming the liberty for appellants to evaluate other parties' cases on their own merits in accordance with the law. The appeals were dismissed, with the Court keeping the question of law open for future consideration.

Scope of Declaration: The Court further delved into the scope of the declaration made by the Division Bench, emphasizing its limited applicability to parties directly involved in the appeals. The Division Bench's declaration was not intended as a blanket statement encompassing all institutions, but rather a specific ruling tailored to the petitioners in the Writ Petitions. This nuanced approach underscored the Court's intention to address the cases before it without extending the declaration universally to all institutions. By maintaining this distinction, the Court upheld the specificity and targeted nature of the relief granted by the Division Bench, ensuring a case-by-case assessment for parties not directly party to the appeals.

Liberty to Consider Cases Independently: In addition to interpreting the relief and declaration, the Supreme Court highlighted the liberty granted to appellants to independently evaluate cases of parties not present before the Court. This liberty underscored the Court's commitment to ensuring a fair and individualized assessment of each case in accordance with the law. By affirming this liberty, the Court reinforced the principle of due process and the need for a thorough examination of cases beyond those directly involved in the appeals. This approach aimed to uphold the integrity of the legal process while allowing for a comprehensive review of all relevant cases, maintaining fairness and adherence to legal standards.