Delhi High Court High Court

Delhi Petrol Dealer Association & … vs Union Of India & Ors. on 18 August, 1999

Delhi High Court
Delhi Petrol Dealer Association & … vs Union Of India & Ors. on 18 August, 1999
Equivalent citations: 1999 VAD Delhi 365, 81 (1999) DLT 400
Author: C Nayar
Bench: C Nayar


ORDER

C.M. Nayar, J.

1.
This judgment will dispose of two petitions, C.W.P. No. 2876/98 and C.W.P. No. 5753/98 as common questions arise for consideration in these petitions.

2. The first petition, C.W.P. No. 2876/98 impugns the revised Marketing Discipline Guidelines which became effective from 12th May, 1998 and the second petition C.W.P. No. 5753/98 challenges the same guidelines as well as the earlier guidelines issued in the year 1995.

3. Petitioner No. 1 in the first petition is stated to be an Association of about 300 persons who are running petroleum products retail outlets commonly known as petrol filling-cum-service stations. There are four oil companies which are under the control of the respondent, namely, Ministry of Petrolium and Oil and Natural Gas, Government of India. These companiesare as follows:-

(a) Indian Oil Corporation Ltd.

(b) I.B.P. Company Ltd.

(c) Bharat Petroleum Corporation Ltd.

(d) Hindustan Petroleum Corporation.

4. It is next stated that all the above four Government companies are under the control of Ministry of Petroleum and Oil and Natural Gas and have been given the responsibility for sale and distribution of motor spirit commonly known as high speed diesel and other petroleum products through retail outlets. The said respondent is empowered to take the decision for opening of new retail outlets and the proportionate allocation of the above mentioned four oil companies. The oil companies, on the basis of the allocation made by the respondent Ministry appoints dealers for the opening of new retail outlets, in most of the cases, by developing and employing all the necessary infrastructure, plant and machinery etc., at the retail outlets. Thereafter the oil companies enter into a dealership agreement with the concerned person for running the retail outlet. As such all the members of petitioner No.1 are operating retail outlets with a dealership
agreement with the aforesaid oil companies. The agreement incorporates in detail the terms and conditions on which members of petitioner No. 1 are under an obligation to run their retail outlets. Their activities are governed and regulated by those terms and conditions which form part of the dealership agreement. A specimen copy of the dealership agreement is filed as Annexure-P1 to the writ petition. It is next submitted that the field relating to import, transport, storage, production, reviving and blending of petroleum is governed by the provisions of Petroleum Act, 1934 and also Petroleum Rules, 1976 as made under the Act. A perusal of the Act and the Rules will show that the legislature has laid down effective mechanism and control relating to supply of petroleum products, maintenance of the quality during the distribution thereof. The petroleum retail outlets are also subject to the provisions of the Weights & Measures Act. The application of
the enactments as referred to above is elaborated in paragraphs 9, 10 and 11 of Civil Writ Petition No. 2876/98 which read as follows:-

“9. That the petitioners respectfully reiterate that all the Oil dispensing units which are installed at the petroleum pump are installed and maintained by the respective Oil Companies. These dispensing units are continuously managed by the Oil Companies with the cooperation of the officers under the Weight and Measure Act. In fact, it is the officers who work under the Weight and Measures and who calibrate and seal these dispensing unit which has been installed at the petroleum retail outlets by the respec tive oil industries.

10. That the petitioners respectfully submit that for propersupply, distribution and maintaining the quality, these legislative provisions provide a complete and self-contained code and does not require the invocation of any other legislative provision. In view of these specific legislation provided by the legislature, it is respectful submissions of the petitioner, that the respondent is not required to resort/have recourse to any other legislature or any statutory provisions. The petitioners submit that both for the maintenance of correct quantity and quality of the petroleum products being sold and distributed from the retail outlets are governed by the above mentioned two legislation.

11. That under the provisions of these enactments, namely, thePetroleum Act and Rules and the Weight and Measures Act, the officers of the Oil Companies, the Ministry and joint Industries (of the four oil companies put together) functioning under the respondent Ministry, carry out for regular checks, inspection and verification with regard to the maintenance of quantity and quality for sale and distribution of quality for sale and distribution of petroleum products from retail outlets at different hierarchical levels. The different levels on which these officers are discharging their duties are stated as under:

(a) There is an Area Sales Officer appointed by the respective oil companies who is charged with the obligation to carry out check, inspection and verification with regard to the quantity and quality of petroleum products sold and distributed from the petrol pumps:

(b) The officers at the managerial level in all the oil companies are also carrying periodical checks and inspection with a view to ensure that the area Sales Officer are doing their job effectively.

(c) The joint industry namely, the officers of all the four oil companies jointly carry out the check and inspection of the retail outlets unit being run under the Control of other oil companies.

(d) The officers under the Weight and Measures Act carry out heir check and inspection independently through Zonal Officer,and also through joint inspection team consisting of Zonal Officers of other oil companies.

(e) The Deputy Controller and Chief Controller under the Weight and Measure Act also carry out independent check and inspection of these petroleum products. It is submitted that almost on all the occasion the inspection and check by the senior officials are surprised inspection so as to effectively achieve the objective sought to be done under the Act. The petitioners, therefore, respectfully submit that these legislations provide for both maintenance and quantity and quality of the petroleum products to be sold from these retail outlets and as such the legislature has provided a complete code for achieving these purpose for these specific items.”

5. Similar reference is made to the provisions of Essential Commodities act by which in exercise of powers under Section 3, the Central Government issued an order namely Motor Spirit and High Speed Diesel (Prevention of Malpractive in Supply and Distribution) Order 1990 which was subsequently amended in the year 1993. The main grievance of the petitioners is that the respondents can take recourse to the provisions of the above enactments and there is no need to frame the Marketing Discipline Guidelines as sufficient provisions are made to check the malpractive in the trade. Paragraphs 13,14 and 15 of the Civil Writ Petition No. 2876/98 read as follows:

“13. That both the dealership agreement and the provisions of the control Order provide that the dealer is entitled to receive petroleum product at his retail outlets in a sealed manner, seal being put by the oil companies. The dealer is not responsible for the quantity and quality of the products before it is received by the dealer at the retail outlets through the transporter duly appointed by the Oil Companies.

14. That the provisions of the control order provide for products supplied and transportation, power of search and seizure, sampling of products etc. Without prejudice to the rights and contentions of the petitioners that in view of the substantive legislature, as mentioned above, already occupying the field, the government could not have invoked the powers under Section 3 of the Essential Commodities Act. It is submitted that the powers under the Essential Commodities Act can be used sparingly for maintaining the supply and distribution of the Essential Commodities. The powers under the Essential Commodities Act
is normally exercised for short duration and for dealing with a situation which arise temporarily causing prejudice to the main tenance and supply of Essential Commodities. The petitioners respectfully submit that the power under the Essential Commodities Act cannot be exercised as a permanent measure and specially in view of the fact that the field is already occupied by sub stantial legislation provided by the legislature as in the present case.

15. That without prejudice to the contention of the petitioner that under the circumstances, the Central Government could not have had exercised the powers under the provisions of Essential Commodities Act, it is respectfully submitted that even if for the sake of argument it is presumed that the Control Order 1990 as amended Order 1993 is valid and legal, it is respectfully submitted that it does not provide for any penal provision as the same have been duly provided under the Petroleum Act and Rules and also under the Weight and Measure Act which apply with full force to the activities of the petitioners and the members of the Petitioner No.1 association.”

6. The challenge to the guidelines is elaborately stated in paragraphs 17 to 20 which may be reproduced as follows:-

17. A perusal of this order clearly shows that this order is neither issued in exercise of any statutory provision nor it has sanctity of any statutory provisions. It is, therefore, clear that the impugned order dated 12.5.1998 is only an executive instruction which does not have the force of law or any statutory character behind it.

18. That the petitioners respectfully submit that the provisions of this Revised Market Discipline Guidelines 1998 are absolutely ultra vires, unconstitutional, arbitrary and irrational. The provision of these 1998 guidelines are also contrary to the terms and conditions of the dealership agreement and also to the above mentioned statutory provisions and are thus not sustainable.

19. These guidelines provided for such stringent provision including heavy amounts of penalties and automatics termination of the dealership agreement, are contrary to law and are abso lutely arbitrary and irrational.

20. That the petitioners respectfully reiterate that they do not dispute the maintenance of supply of correct quality and quantity of petroleum products and making available of other basic and community facilities to the customers. The petitioners in the following paragraphs would demonstrate the arbitrariness and irrationality of these impugned guidelines.

(A) Dispensing units at the petrol pumps are owned and maintained by the oil company. They are calibrated and seals are put by the officers of the Weight and Measure Department. It is also admitted position that despite certification by the oil companies and the manufacture of these dispensing units, these machines are capable of and erratic delivery at different temperature at different condition etc. In any case the complete mechanism to deal with any deliberate short supply of the petroleum products has been provided for under the Weights and Measures Act.

(B) Insofar as the quality of the petroleum products is concerned, it is respectfully submitted that the dealers are entitled to receive petroleum products through sealed tanker provided by the oil companies at their retail outlets. The quality of the petroleum products as being received at the retail outlets is tested by way of checking the density of the petroleum products as mentioned on the invoice issued by the oil companies. It is submitted that it is the only test which can be carried out at the retail outlets. Under the provisions of the impugned order every dealer is required to maintain density record register wherein the density of every supply received from the oil companies depot is to be mentioned on receipt of the products and the density of the products in the tank in the morning everyday is to
be recorded there. The dealer is therefore under an obligation to sell the petroleum product of such density which had received from the oil company. It is only in the case any variance beyond a permissible limit in the density of the petroleum products that the officers of the oil company also are entitled to take sample from the retail outlets for further investigation and suitable action is also provided in the dealership agreement.

(C) It is respectfully submitted that the dealer is obliged to ensure that it is selling the petroleum products at such density which it had received from the oil company and maintained the density record on the daily base as per the format provided by the oil company. If the dealer is able to show that it is selling the petroleum products at the same density level as it has received the same from the oil company neither the dealership agreement nor any of the provisions of law occupying the field as enumerated above, provided any penal action against the dealer. Earlier also when the respondent had tried to impose arbitrary provisions for taking samples despite the density being found in order, the Ministry by its office order dated 12.9.96 had clarified that the staff of the oil companies would not entitled to
take samples in that situation.

(D) These revised guidelines also provide for heavy penalty for the alleged discourteous behavior and for non-providing first aid and toilet facility. It is submitted that all these facilities for toilet etc. are to be provided by the oil company. At a side namely where the retail outlets are owned by the oil companies, the dealer cannot be penalised for some deficiencies in this regard. The ground of discourteous behavior empowering the authority to impose heavy penalty and cancel the licence is absolutely arbitrary, irrational and ultravirus. The petitioners
submit that no doubt that the employees of the dealers are required to maintain minimum level of courtesy to the customer. For every discourteous behavior, when staff is dealing thousand and thousand customers a day, inviting penal measures are absolutely arbitrary, ultra vires and unsustainable.

(E) That the calculation for distributing the petroleum products go even in the paise. It is a matter of common knowledge that the smaller denomination coins are not easily available. The settling of accounts with every customer in paise is not possible. At so many times the customers are required to pay a few paise more or few paise less. In certain events there are bona fide mistake in putting the correct number of paise in the case memo. Even in such cases the revises guidelines proposed measure penalty termination of the dealership licence.

(F) The petitioners respectfully submit that these revised guidelines provide for minor and major penalty which are without any authority and sanction of law and the guideline even do not specify what are the minor discrepancies and what are the major discrepancies including the minor and major penalties respective ly.

(G) That the entire infrastructure and lay out to the equipment at the retail outlets is provided by the oil company. The oil company take the permission under the explosive Act for which the dealer has no say. The guidelines now provide that if the authority under the explosive Act find any discrepancy in the lay out and providing infrastructure and equipment, that will become a ground for the oil company to take penal action against the dealership to minate the licence.

(H) That the revised guidelines, without prejudice to the contention of the petitioners that it is unconstitutional, ultra vires, no where provide even a minimum semblance of reasonable opportunity to the dealer of being heard before any penal action is taken.

On 31.5.1998, i.e. Sunday, three members of the petitioner No.1 association have been directed to suspend their operation, in purported exercise of power under the revised guideline and without having given any opportunity to them of hearing before they were directed to suspend their operation.

(I) The guidelines provided for surprise check and in the event of non-production of record the guidelines provide for termination of the licence. It is submitted that the production of record at the surprise visit while the office of the petrol pump is closed, can never invite such drastic and penal action because the dealer can always provide the record if asked by the inspection team within a reasonable time. The disability of the staff of the dealer at surprise visit at odd hours when the records can never be produced, cannot be the basis for any penal action including termination of the licence.”

7. Firstly reference may be made to the relevant provisions of the dealership agreement which is filed as Annexure-P1 to the writ petition.Clauses 13, 25, 26, 30, 38, 43 and 56 of the agreement make the following reading:-

“13. The Corporation has installed at its own expense at and under the premises the outfit described in the Second Schedule hereunder written. The Corporation may install at the premises such other apparatus and equipment from time to time as it may deem necessary for the efficient working of the retail outlet and all such other apparatus and equipment shall be deemed to be and form part of the outfit. Provided that the Corporation shall have the right to remove any particular item or items of apparatus or equipment comprised in the outfit without assigning any reason
therefore.”

“25. The quantities of petroleum and other allied products stated to be delivered by the Corporation as measured by the Corporation’s measuring devices or means shall be final and binding upon the parties hereto. A receipt signed by or on behalf of the Dealer at the time of delivery by the Corporation of petroleum products will be conclusive evidence that the petroleum products mentioned therein were in fact delivered to the Dealer, that such products were in accordance with the specifications therefore mentioned hereunder and that the quantities of such
products mentioned in the receipt are correct, and the Dealer shall thereafter be precluded from making any claim against the Corporation for compensation of otherwise on the ground of short delivery or contamination of such products.

26. The Dealer shall be responsible for all loss, contamination, damage or shortage of or to the products, whether partial or entire, and no claim will be entertained by the Corporation therefore under any circumstances except in cases where the Corporation is satisfied that loss arose from leakage from underground tanks or pipes which the Dealer could not reasonably have discovered and of which the Dealer gave immediate notice to the Corporation on discovery.”

30. The Dealer shall not make supplies of petroleum products of the Corporation to any other person/firm or company whose supplies have been stopped by the Corporation.”

“38. The Corporation will be entitled at all times to enter into and inspect the management of the retail outlet by the said Dealer in all respects and the Dealer shall be bound to render all assistance and give all information to the Corporation and its duly authorised representatives in that behalf.”

“43. The Dealer undertakes faithfully and promptly to carry out, observe and perform all direction or rules given or made from time to time by the Corporation for the proper carrying on of the dealership of the Corporation. The Dealer shall scrupulously observe and comply with all laws, rules, regulations and requisitions of the Central/State Governments and of all authorities appointed by them or either of them including in particular the Chief Inspector of Explosive, Government of India, and/or Municipal and/or any other local authority with regard to the storage and sale of such petroleum products.”

“56. Notwithstanding anything to the contrary herein contained, the Corporation shall be at liberty to terminate this Agreement forthwith upon or at any time after the happening of any of the following events, namely:-

(a) If the Dealer shall commit a breach of any of the covenants and stipulations contained in the Agreement, and fail to remedy such breach within four days of the receipt of a written notice from the Corporation in that regard.

(b) Upon

(i) the death or adjudication as insolvent of the Dealer, if he is an individual;

(ii) the dissolution of the partnership of the Dealer’s firm on the death or adjudication as insolvent of any partner of the firm, if the Dealer be a firm;

(iii) the liquidation whether voluntary or otherwise of the passing of an effective resolution for winding up, if the Dealer be a Company or Co-operation Society.

(c) If any attachment is levied and continued to be levied for a period of seven days upon the effect of the Dealer or any individual partner for the time being of the Dealer’s firm or any member of the Dealer Co-operative Society.

(d) If the Dealer or any partner in the Dealer’s firm or any member of the Co-operative Society appointed as Dealer hereunder hall be convicted of a criminal offence.

(e) If a Receiver shall be appointed of any property or assets of the Dealer or of any partner in the Dealer’s firm of any member of the Dealer Co-operative Society.

(f) If the licence issued to the Dealer by the relevant authori ties for the storage of petroleum products supplied by the Corporation is canceled or revoked.

(g) if the Dealer shall for any reason make default in payment to the Corporation in full or his outstanding as appearing in Corporation’s books of accounts beyond 4 days of demand by the Corporation.

(h) If the Dealer does not adhere to the instructions issued from time to time by the Corporation in connection with safe practices to be followed by him in the supply/storage of the Corporation’s products or otherwise.

(i) If the Dealer shall deliberately contaminate or tamper with the quality of any of the Corporation’s products.

(j) If the Dealer shall sell the Corporation’s products at prices higher than those fixed by the Corporation.

(k) If the Dealer shall either by himself or by his servants or Agents commit or suffer to be committed any act which, in the opinion of the Executive Director of the Corporation for the time being in whose decision shall be final, is prejudicial to the interest or good name of the Corporation or its products; the General Manager shall not be bound to give reasons for such decision.

(l) If any information given by the Dealer in his application for appointment as a Dealer shall be found to untrue or incorrect in any material respect.

The Corporation’s right to terminate this Agreement under the terms of this clause shall be without prejudice to any of its other rights and remedies against the Dealer. In the event of the Corporation terminating this Agreement under the provisions of this clause, it shall not be liable to pay for any loss or compensation in respect of such termination PROVIDED THAT the supply of any petroleum products by the Corporation to the Dealer, pending expiry of any notice of termination or after any act,contravention or omission by the Dealer entitling the Corporation
to terminate this Agreement shall have become known to the Corporation shall not in any way prejudice or affect the right of the Corporation to revoke and/or enforce the termination of this Agreement and the licence granted hereunder.”

8. The learned counsel for the petitioners has argued that the respondents can only act under the provisions of clause 43 of the agreement and cannot formulate their own guidelines by introducing new set of penalities which are not prescribed in any of the Statutes such as the Petroleum Act,weights & Measures Act and the Essential Commodities Act. The salient features of the impugned guidelines effective from 12th May, 1998 are filed as Annexure-P6 to the writ petition. The petitioners are prima facie aggrieved by the imposition of fines for major and minor irregularities as it
is contended that these cannot be justified as no statutory power is vested in the Authorities to impose such penalties. The irregularities as referred to in the guidelines as well as the proposed punishments as stated in CHAPTER-6, titled “PREVENTION OF IRREGULARITIES AT RETAIL OUTLETS (MS/HSD) ” relating to major and minor irregularities may be reproduced as follows:-

“CHAPTER 6

PREVENTION OF IRREGULARITIES AT RETAIL OUTLETS (MS/HSD)

MAJOR IRREGULARITIES :

1. ADULTERATION OF PRODUCT:

Definition:

“Adulteration” means the introduction of any foreign substance into motor spirit/high speed diesel illegally or unauthorisedly with the result that the product does not conform to the requirements indicated in Appendix “B”.

(a) Individual Oil Company Officers should carry out density checks and furfural checks (wherever applicable) at the Retail Outlets as per the prescribed guidelines. Moreover on random basis, at the discretion of the Inspecting Officer, samples may be drawn for clinical tests/RON, even if the density matches.

(b) If density check or furfural check (wherever applicable) indicates possible adulteration:

Sales and supplies of all products to be suspended immediately till such time investigations are completed. Meter and dip readings should be recorded in the inspection Report duly signed by the Dealer or his representative together with rubber stamp of dealership and each page of the inspection report shall be initialed by Inspecting Officer and Dealer/Dealer’s representative. Dispensing Pumps and Tanks should be sealed.

(c) Wherever samples are drawn, either pursuant to random checks or where adulteration is suspected, 3 sets of signed and sealed samples (6×1 ltr. of MS and 3×1 ltr. of HSD) should be collected from the RO, out of which one set should be kept with the dealer, one with the company and the third to be sent for laboratory testing within 10 days. For the sample kept with the dealer, proper acknowledgement will be obtained and the dealer will be instructed to preserve the sample in his safe custody till the
testing/investigations are completed.

It is necessary that the Officer sending the sample should inform the dispatching location concerned to retain the reference sample drawn from TLF of the particular date of dispatch of the T/T to the concerned Retail Outlet corresponding to the sample being tested.

The laboratory test will be done at any Industry Laboratory to determine variations in any of the following parameters as compared to sample of product supplied. Reference for Density would, however, be Density of product after last receipt:

TEST METHOD
IS : 1448
Motor Spirit : Tests
(1) Appearance Visual
(2) Colour Visual
(3) Density @ 15C P-16
(4) Distillation P-18
IBP Degree C
Recovery upto 70 Degree C % V
Recovery upto 100 Degree C % V
Recovery upto 180 Degree C % V
Final Boiling Point Degree C
Residue, % V
(5) Existent gum P-29
(6) RON* P-27
*Refinery will carry out only Octane Number test. Wherever Octane
Number test facility is available in marketing laboratory, the
same shall be carried out at the marketing laboratory.

     High Speed Diesel   :    Tests
     (1)  Appearance               Visual
     (2)  Colour                   Visual 
     (3)  Density @ 15 decree C    P-16
     (4)  Kinematic Viscosity 
     CS at 40 Degree C        P-25
     (5)  Distillation, 90%
     volume recovery
     at Degree C max.         P-18
 


The above mentioned tests will be carried out as per standard Test methods as given in the Bureau of Indian Standard Specification, IS : 1448 : P- Methods for respective tests.

The above test-results on the sample taken from the Retail Outlet/Tank Truck should be within the reproducibility limits of the test-method when compared to the reference sample, at dispatching location.

(d) If the sample passes the lab. test, including RON in case of MS, sales and supplies of all products, if suspended earlier, will be resumed to the dealer immediately.

If the sample is certified to be adulterated, after laboratory test, a show-cause notice should be served on the dealer and explanation of the dealer sought within 7 days of the receipt of the show-cause notice. If the explanation of dealer is not satis factory, the Company should take action as follows:

(i) Fine of Rs. 1 lakh and suspension of sales and supplies for 45 days the first instance.

(ii) Termination in the second instance.

(e) Handling of Adulterated Product.

In case of proven adulteration, the product (MS/HSD) will be taken back by the concerned Oil Company to the nearest location where separate storage facilities for handling such adulterated product are available. The product will be corrected in consultation with QC Department of the Region. Entire expenses towards transportation, pumping of product, tank cleaning, incidental charges, local levies, etc. will be borne by the dealer.

In cases where product is upgraded to MS or downgraded to HSD, the dealer will be paid an amount equivalent to the cost of HSD. In cases where the product is downgraded to other than HSD, the dealer will be paid an amount equivalent to the cost of downgrad ed product.

In both the above cases, credit will be given only for the quantity actually upgraded/downgraded. Any losses, etc. will be borne by the dealer.

2. SHORT DELIVERY OF PRODUCTS:

When Weights & Measures seals are tampered with:

(i) Suspension of sales and supplies of all products for 30 days alongwith a fine of Rs. 50,000/- in the first instance.

(ii) Fine of Rs.1 lakh and suspension of sales and supplies of all products for 45 days in the second instance.

     (iii)     Termination in the third instance. 
 


     3.   STOCK VARIATION 
 


     MS and HSD
 


Stock reconciliation should be carried out and variation, if any, established after taking into account the normal variation in operational levels of +/- 4% of tank stock and after considering the following factors:

(i) Evaporation/handling losses in MS as follows:

0.75% on quantity sold upto an annual average of 600 KLs.

0.60% on additional quantity beyond an annual average 600 KLs.

(ii) Handling losses in HSD as follows:

0.25% on quantity sold upto an annual average of 600 KLs.

0.20% on additional quantity beyond an annual average of 600 KLs.

(iii) Shrinkage losses on MS/HSD temperature variation allow ance (TVA) quantities on MS and HSD to be taken into account (only in those cases/locations where and when the TVA is applica ble).

In case there is variation in stocks beyond the permissiblelimits, sales and supplies of all products to be suspended immediately, samples to be drawn and sent for testing within 10 days as well as dealer’s explanation to be called for within 7 days.

If explanation is unsatisfactory:

(i) Suspension of sales and supplies of all products for 30 days longwith a fine of Rs. 50,000/- in the first instance.

(ii) Fine of Rs.1 lakh and suspension of sales and supplies of all products for 45 days in the second instance.

(iii) Termination in the third instance.

4. UNAUTHORISED PURCHASES/SALES/EXCHANGE OF MS, HSD OR ANY OTHER PRODUCT WHICH COULD BE USED AS A SUBSTITUTE FOR THESE
PRODUCTS

Seek dealer’s explanation within 7 days. In case, the explanation is not satisfactory:

(i) Suspension of sales and supplies of all products for 30 days alongwith a fine of Rs. 50,000/- in the first instance.

(ii) Fine of Rs.1 lakh and suspension of sales and supplies of all products for 45 days in the second instance.

(iii) Termination in the third instance.

5. NN-AVAILABILITY OF REFERENCE DENSITY AND/OR SAMPLES OF LAST SUPPLY AT THE TIME OF INSPECTION

Sales and supplies of all products to be suspended immediately, samples to be drawn and sent for testing within 10 days.

In case product meets specification, sales and supplies of all products to be resumed with a warning letter.

In case of product being off spec:

(i) Suspension of sales and supplies of all products for 30 days alongwith a fine of Rs. 50,000/- in the first instance.

(ii) Fine of Rs.1 lakh and suspension of sales asd supplies of all products of 45 days in the second instance.

     (iii)     Termination in the third instance. 
 


     6.   TOTALISER SEALS IF FOUND TAMPERED WITH
 


(i) Suspension of sales and supplies of all product of 30 days alongwith a fine of Rs. 50,000/- in the first instance.

(ii) Fine of Rs.1 lakh and suspension of sales and supplies of all products for 45 days in the second instance.

     (iii)     Termination in the third instance. 
 


     MINOR IRREGULARITIES
 


     1.   OVERCHARGING IN AUTHORISED SELLING PRICES OF MS/HSD
 


     (a)  Dealer to be advised to charge correct prices. 
 


(b) Seek dealer’s written explanation within 7 days. If the explanation is not satisfactory:

(i) Suspension of sales and supplies of all products for 15 days alongwith a fine of Rs. 20,000/- in the first instance.

(ii) Suspension of sales and supplies for 30 days alongwith a fine of Rs. 50,000/- in the second instance.

(iii) Suspension of sales and supplies of all products for 45 days alongwith a fine of Rs. 1 lakh in the third instance.

2. SHORT DELIVERY OF PRODUCTS

When Weights & Measures seals are intact but deliveries are below tolerance limit:

(a) Sales and supplies should be stopped from the Dispensing unit till recalibration is carried out by Weights & Measures department.

(b) (i). Suspension of sales and supplies of all products for 15 days alongwith a fine of Rs. 20,000/- in the first instance.

(ii) Suspension of sales and supplies for 30 days alongwith a fine of Rs. 50,000/- in the second instance.

(iii) Suspension of sales and supplies of all products for 45 days alongwith a fine of Rs. 1 lakh in the third instance.

iv) In extreme cases, where it is proved that the dealer has tampered with the delivery system, termination will be considered in the fourth instance.

3. PROVISION OF UNAUTHORISED STORAGE FACILITIES

In case of detection of storage facilities not approved by the Company and/or not in accordance with Explosive’s approval:

(a) Sales and supplies of all products to be suspended with immediate effect.

(b) Show-cause notice to be issued to the dealer calling for a written explanation within 7 days.

(c) If written explanation is not satisfactory:

(i) Suspension of sales and supplies of all products for 15 days alongwith a fine of Rs. 20,000/- in the first instance.

(ii) Suspension of sales and supplies for 30 days alongwith a fine of Rs. 50,000/- in the second instance.

(iii) Suspension of sales and supplies of all products for 45 days alongwith a fine of Rs.1 lakh in the third instance.

4. NON-OBSERVANCE OF GOVT. REGULATIONS AND COMPANY’S OPERATING GUIDELINES/INSTRUCTIONS, IF ANY, ON SALE AND DISTRIBUTION OF PETROLEUM PRODUCTS

For non-observance of Govt. regulations like Essential Commodities Act, Explosives Act, Petroleum Act and Control Orders, a written explanation is to be sought from the dealer which f found to be satisfactory, no action to be taken. However, if explanation is found not satisfactory, the following to be done:

(i) Suspension of sales and supplies of all products for 15 days a longwith a fine of Rs. 20,000/- in the first instance.

(ii) Suspension of sales and supplies for 30 days alongwith a fine of Rs. 50,000/- in the second instance.

(iii) Suspension of sales and supplies of all products for 45 days alongwith a fine of Rs. 1 lakh in the third instance.

5. NOT PRODUCING FOR INSPECTION STOCK/SALES REGISTERS AT THE TIME OF SURPRISE CHECK

(i) Suspension of sales and supplies of all products for 15 days alongwith a fine of Rs. 20,000/- in the first instance.

(ii) Suspension of sales and supplies for 30 days alongwith a fine a Rs. 50,000/- in the second instance.

(iii) Suspension of sales and supplies of all products for 45 days alongwith a fine of Rs. 1 lakh in the third instance.

6. NON PROVISION OF FREE AIR, DRINKING WATER, RADIATOR WATER, TOILET FACILITIES, TELEPHONE (WHERE POSSIBLE), FIRST-AID, PUC (WHERE APPLICABLE) AT RO PREMISES, THE FOLLOWING ACTION TO BE TAKEN (IN EXCEPTIONAL CASE WHERE TOILET FACILITIES CANNOT BE PROVIDED BECAUSE OF MUNICIPAL AND OTHER RESTRICTIONS, SUITABLE LETTER TO BE ISSUED TO DEALER TO AVOID DISCIPLINARY ACTION).

(i) Fine of Rs. 10,000/- in the first instance.

(ii) Fine of Rs. 30,000/- in the second instance.

(iii) Suspension of sales and supplies for 45 days alongwith a fine of Rs.1 lakh in the third instance and thereafter for every
subsequent similar offence.

7. ESTABLISHED CASES OF DISCOURTEOUS BEHAVIOR BY DEALER AND/OR
HIS STAFF, NON-PRODUCING OF SUGGESTION/COMPLAINT BOOK

(i) Fine of Rs. 10,000/- in the first instance.

(ii) Fine of Rs. 30,000/- in the second instance.

(iii) Suspension of sales and supplies for 45 days alongwith a fine of Rs. 1 lakh in the third instance and thereafter for every subsequent similar offence.

8. ESTABLISHED CASES OF ISSUANCE OF FAKE PUC CERTIFICATES BY DEALERS HAVING PUC FACILITIES

(i) Suspension of sales and supplies of all products for 15 days alongwith a fine of Rs. 20,000/- in the first instance.

(ii) Suspension of sales and supplies for 30 days alongwith a fine of Rs. 50,000/- in the second instance.

(iii) Termination in the third instance.

NOTE:

(i) The above are general guidelies and notwithstanding what has been stated above, the competent Authority of the concerned Oil Company can take appropriate higher punitive action against the erring dealer including termination in the first or any instance.

(ii) Every punitive action would be taken after show cause notice of minimum seven days.

(iii) The cycle of calculating second and third instance shall be five years starting from the date of first irregularity.

(iv) In case, two or more irregularities are detected at the same item at the same RO, action will be taken in line with what is listed in the MDG under the relevant category for each irregularity.

(v) All irregularities established under “Major” and “Minor” categories will be treated separately for the purpose of imposing penalties.

(vi) Filed staff should ensure that samples for testing are sent to the Laboratory within 10 days of drawal of the same. Lab. test reports should thereafter be made available within ten days.

(vii) In case of irregularities not specifically mentioned/covered above, the competent/appropriate authority of the concerned Oil Company shall impose proper penalty and/or issue warning letter after enquiry and in accordance with the principles of natural justice.

(viii) Under existing laws, Control Orders etc., various authorities of Central Government/State Government-in addition to Oil Company officers – are empowered to carry out checks of the dealership for determining and securing compliance with such laws/Control Order. If any “malpractice or irregularity” is established by such authorities after checking, the same would also be taken as a “malpractive or irregularity” under these guidelines and prescribed punitive action would be taken by the Oil Company, on receipt of advice from such authority.

(ix) Wherever fine with suspension has been provided, fine must be paid within suspension period, failing which suspension would be extended by the equivalent period. If fine is not paid even within the extended period, the dealership would be terminated.”

9. The following grounds are urged by learned counsel for the petitioners assail the punishments as proposed in the guidelines and as referred to above:-

(i) The exercise of executive power must have a legitimate source of power which may either be contractual or statutory. In the present case the Statutes provide penalties and punishments and the respondents have to move within that framework. The agreement also does not provide any imposition of fines on the members of the petitioner Association and, therefore, the guidelines cannot be sustained.

(ii) If there are two kinds of powers only less onerous may be applied and the petitioners are entitled to the benefit of such exercise.

(iii) The guidelines are arbitrary, irrational and cannot be sustained as no provision of hearing or fair procedure has been prescribed. Reliance is placed on the judgments reported as Maganlal Chhaganlal (P) Ltd. Vs. Municipal Corporation of Greater Bombay and others, (1974) 2 Supreme Court Cases 402; M/s. Khemka & Co. (Agencies) Pvt. Ltd. Vs. State of Maharashtra ; Ahmedabad Urban Development Authority Vs. Shrad Kumar Jayanti Kumar Pasawalla and others, .

10. Paragraphs 6 and 14 of the judgment in the case of Maganlal Chhaganlal(P) Ltd. (supra) may be reproduced as follows:

“6. The argument based on the availability of two procedures,one more onerous and harsher than the other and, therefore, discriminatory has led some High Courts to resort to various reasoning in order to get round the effect of the decision in the Northern India Caterers case (supra). This has happened in the case of the Madras High Court in Abdul Rashid Vs. Asstt. Engineer (Highways), the Andhra Pradesh High Court in M. Begum Vs. State and Meharunnissa Begum Vs. State of Andhra Pardesh and the Patna High Court in Bhartiya Hotel Vs. Union of India. The decision of the Patna High Court is one of the cases which was considered along with Hari Singh’s case (supra). It is rather interesting
that this attack based on Art. 14 of the Constitution should have led to the apparently more onerous and harsher procedure becoming the rule, the resort to the ordinary Civil Court being taken away altogether. It is difficult to imagine who benefits by resort to the ordinary Civil Courts being barred. One finds it difficulties to reconcile oneself to the position that the mere possibility of
resort to the Civil Court should make invalid a procedure which would otherwise be valid. It can very well be argued that as long as a procedure does not by itself violate either Art. 19 or Art. 14 and is thus constitutionally valid, the fact that procedure is more onerous and harsher than the procedure in the ordinary Civil Courts, should not make that procedure void merely because the authority competent to take action can resort to that procedure in the case of some and ordinary Civil Court procedure in the case of others. That a constitutionally valid provision of law should be held to be void because there is a possibility of its being resorted to in the case of some and the ordinary Civil
Court procedure in the case of others somehow makes one feel uneasy and that has been responsible for the attempts to get round the reasoning which is the basis in the decision in North ern India Caterers case (supra).”

“14. To summarise: Where as statute providing for a more drastic procedure different from the ordinary procedure covers the whole field covered by the ordinary procedure, as in Anwer Ali Sarkar’s case and Suraj Mall Mohta’s case without any guidelines as to the class of cases in which either procedure is to be resorted to, the statute will be hit by Art. 14. Even there,as mentioned in Suraj Mall Mohta’s case (supra) a provision for appeal may cure the defect. Further, in such cases if from the preamble and urrounding circumstances, as well as the provisions of the statute themselves explained and amplified by affidavits, necessary guidelines could be inferred as in Saurashtra case (supra) and Jyoti Pershad’s case (supra) the statute will not be hit by Art. 14. Then again where the statute itself covers only a class of cases as in Haldar’s case (supra) and Bajoria’s case (supra) the statute will not be bad. The fact that in such cases the executive will choose which cases are to be tried under the special procedure will not affect the validity of the statute. Therefore, the contention that the mere availability of two procedures will vitiate one of them that is the special procedure, is not supported by reason or authority.”

11. Reference is made to paragraph 39 of the judgment in the case of M/s.Khemka & Co. (Agencies) Pvt. Ltd. (supra) which reads as under:-

“39. On a consideration of the provisions mentioned above, it seems to me to be clear that whatever may be the objects of levying a penalty, its imposition gives rise to a substantive liability which can be viewed either as an additional tax or as a fine for the infringement of the law. The machinery or procedure for its realisation comes into operation after its imposition. In any case, it is an imposition of a pecuniary liability which is comparable to a punishment for the commission of an offence. It is a well settled canon of construction of statutes that neither a pecuniary liability can be imposed nor an offence created by mere implication. It may be debatable whether a particular proce dural provision creates a substantive right or liability. But, I do not think that the imposition of a pecuniary liability, which takes the form of a penalty or find for a breach of a legal obligation, can be relegated to the region of mere procedure and machinery for the realisation of tax. It is more than that. Such liabilities must be created by clear, unambiguous, and express enactment. The language used should leave no serious doubts about its effect so that the persons who are to be subjected to such a liability for the infringement of law are not left in a state of
uncertainty as to what their duties or liabilities are. This is an essential requirement of a good Government of laws. It is implied in the constitutional mandate found in Article 265 of our Constitution : “No tax shall be levied or collected except by authority of law”.”

12. The respondents, it is contended are not empowered to levy fines and penalties when no specific provision is made in various enactments such as the Petroleum Act, Weights & Measures Act and the Essential Commodities Act. Reference is made to paragraphs 7 and 8 of the judgment in the case of Ahmedabad Urban Development Authority (supra) which read as follows:-

“7. After giving our anxious consideration to the contentions raised by Mr. Goswami, it appears to us that in a fiscal matter it will not be proper to hold that even in the absence of express provision, a delegated authority can impose tax or fee. In our view, such power of imposition of tax and/or fee by delegated authority must be very specific and there is no scope of implied authority for imposition of such tax or fee. It appears to us that the delegated authority must act strictly within the parame ters of the authority delegated to it under the Act and it will
not be proper to bring the theory of implied intent or the concept of incidental and ancillary power in the matter of exercise of fiscal power. The facts and circumstances in the case of istrict Council of Jowai are entirely different. The exercise of powers by the Autonomous Jaintia Hills Districts are controlled by the constitutional provisions and in the special facts of the case, this Court has indicated that the realisation of just fee for a specific purpose by the autonomous District was justified and such power was implied. The said decision cannot be made applicable in the facts of this case or the same should not be held to have laid down any legal proposition that in matters of imposition of tax or fees, the question of necessary intendment may be looked into when there is no express provision for imposi-

tion of fee or tax. The other decision in Khargram Panchayat Samiti case also deals with the exercise of ncidental and conse quential power in the field of administrative law and the same does not deal with the power of imposing tax and fee.

8. The High Court has referred to the decisions of this Court in Hingir case and Jagannath Ramanuj case and Delhi Municipal Corporation case. It has been consistently held by this Court that whenever there is compulsory exaction of any money, there should be specific provision for the same and there is no room for intendment. Nothing is to be read and nothing is to be implied and one should look fairly to the language used. We are, therefore, unable to accept the contention of Mr. Goswami.

Accordingly, there is no occasion to interfere with the impugned decision of the High Court. The appeal, therefore, fails and isdismissed with no order as to costs.”

13. On the other hand the learned counsel for the respondents have argued that ample power is provided to frame the guidelines in pursuance to clause 43 of the Agreement. This clause may again be reproduced as under:-

“43. The Dealer undertakes faithfully and promptly to carry out, observe and perform all direction or rules given or made from time to time by the Corporation for the proper carrying on of the dealership of the Corporation. The Dealer shall scrupulously observe and comply with all laws, rules, regulations and requisitions of the Central/State Governments and of all authorities appointed by them or either of them including in particular the Chief Inspector of Explosive, Government of India, and/or Municipal and/or any other local authority with regard to the storage and sale of such petroleum products.”

14. The guidelines were framed to check malpractice and to rationalise and ensure observance of quality, quantity and excellent customer service. The salient features of the guidelines are stated as follow :-

“3. While recommending the increase in the dealers’ commission recently, it was decided that to justify the higher commission, dealers should also provide better services to the customers. Accordingly, it was decided that further more stringent punishment should be provided for various types of irregularities and malpractices, in a rationalised manner to ensure observance of norms of quality, quantity and excellent customer service, Marketing Discipline Guidelines, 1998 have been prepared in accordance with this principle.

4. It was also desired that there should be an effective mechanism for redressal of grievances of consumers. It has been proposed that District Magistrate of every District will be requested to fix a day in each quarter of three months on which, he or his representative may be present in a forum of public functionaries, dealers/distributors and the senior officers of the oil companies and the consumers. The problems and grievances of consumers will be addressed on the spot and further necessary directions given to oil companies and dealers.”

15. Further explanation for the necessity of framing the revised guidelines in 1998 is elaborately stated in additional affidavit dated 7th December, 1998 filed on behalf of the respondent by Shri H.C. Khurana, Under Secretary in the Ministry of Petroleum and Natural Gas. The purpose and the spirit behind revising the earlier guidelines as framed in 1982 and 1985 are stated in paragraphs 2, 3, 4, 5, 6, and 7 which may be reproduced as follows:-

“2. That Marketing Discipline Guidelines are in force for more than a decade and the same were revised from time to time in public interest so as to bring uniformity in guidelines of various Oil Companies, to ensure sale of correct quality and quantity of petroleum products to bring in effective check and balance against adulteration, short supply etc. and to ensure good service to customers.

3. That Marketing Discipline Guidelines were first formulated in the year 1982 with an objective to bring in uniform guidelines for all the four Oil Companies as previously all the four oil companies were having their own guidelines. The other objectives were strict imposition of penal action and fairness in approach/dealings with dealers of various oil companies. Copy of the Marketing Discipline Guidelines, 1982 is annexed hereto and marked as Annexure-A.

4. That the Marketing Discipline Guidelines of 1982 were subsequently revised in 1995, the guidelines of 1982 were not effective in checking adulteration, short supply etc. Further, 1982 Marketing Discipline Guidelines contained only suspension and termination as penal action against the violation of the guidelines and dealership agreements. Therefore, keeping the public interest in view, the 1982 guidelines were revised in 1995 and fines were introduced, as suspension in the first instance even for minor penalty caused undue hardship to the consumers and such action even for minor offences may not have consumerate with the action taken in the interest of petrol dealers. Copy of the marketing Discipline Guidelines 1995 are annexed hereto and marked as Annexure-B.

5. That the Guidelines of 1982 and 1995 were not challenged by the respondent or by any other similar organisations. That the penal actions were taken against the petrol dealers and punish ment were being imposed as per these guidelines which included imposition of fines.

6. That the said guidelines of 1995 were further revised in 1998 as in practice it was realised that to be a deterrent higher rates of fines and more onerous conditions needed to be intro duced which is being impugned by the petitioner herein. That the respondent has prepared a comparative statement of penal actions under Marketing Discipline Guidelines, 1982, 1995 and 1998 showing that only one offence has been newly introduced in the Mar keting Discipline Guidelines of 1998 i.e. Established cases of issuances of fake PUC certificates by dealers having PUC facilities as Minor Offences, in comparison to the Marketing Discipline guidelines of 1995. That all other major/minor offences as provided in the 1998 guidelines were present in 1995 guidelines. However, to ensure honesty and deterrence, more onerous monetari-

al penalties are prescribed to deter violations. Hence, the petitioner’s contention that Marketing Guidelines, 1998 as being ultra vires, unconstitutional and arbitrary is untenable and the petition is liable to be dismissed forthwith. Copy of the comparative statement of penal action under Marketing Discipline Guidelines, 1982, and 1995 and 1998 are being annexed and marked as Annexure-C.

7. That the respondent carried out a Special Vigilance Drive from 29.10.1998 to 2.11.98 to check the malpractices and irregularities taking place in the retail network, oil company installations/Department. Bottling Plants and during transportation of petroleum products. That during the said drive, total sales and supplies of 1364 retail outlets were inspected in 50 towns,throughout the country. That of the total number of retail out lets inspected 323 were detected for short supply, 68 were de tected for adulteration, there were 29 cases of sample failure, and in 663 cases there were non availability of basic facilities like free air water, toilet facilities, complaint box and first aid box. That enroute checking of TTs were carried out in 1289 cases. That of the total number checked irregularities were etected in 113 cases. That 110 terminals were checked and irreg ularities were detected in 60 cases. That inspections were carried out for unauthorised dumps. That of the 13 cases inspected, irregularities were detected in 4 cases. That copy of the report of the Special Vigilance Drive from 29.10.98 to 2.11.98 is being annexed hereto and marked as Annexure-D. That considering the magnitude of irregularities, detected in various retail outlets, it is necessary that the impugned guidelines of 1998 be imple mented in full force, to curb further malpractice and irregulari ties. The 1998 guidelines merely provide more teeth to the existing guidelines to ensure greater enforceability.”

16. The comparative statement of penal action in the three guidelines of 1982, 1985 and 1998 are referred to in Annexure ‘C’ filed with Additional affidavit on behalf of the respondent. The same is reproduced as under:-

“COMPARATIVE STATEMENT OF PENAL ACTIONS UNDER MARKETING DISCIPLINE GUIDE-

LINES 1982, 1995 AND 1998.

PUNISHMENTS              PUNISHMENTS              PUNISHMENTS 
EXISTING                 EXISTING                 EXISTING
IN MDG 1982              IN MDG 1995              IN MDG 1998           
 
MAJOR OFFENCES 
1.  Adulteration  of MS/HSD (Major Offence) Found during  stock  variation, 
Filter Paper Test (for  MS), density check, Furfural check, Mobile Lab check 
etc.,  (Furfural  checks,  Mobile Lab checks and Density  checks  were  not 
introduced in 1982)
If  the sample is certified as adulterated, after laboratory test,  a  show 
cause notice should be served on the dealer.
If the explanation of dealer is not satisfactory :
If MS is suspected       1. Fine of Rs. 10,000/-  1. Fine of Rs.1,00,000/- 
to be adulterated,       along with suspension    and suspension of 
only sales and           of sales and supplies    sales and supplies 
supplies of MS to        of all products for      of all products for 45 
be suspended till        30 days in the first     days in the first 
completion of            instance. instance.      If the fine 
investigations. The      2. Fine of Rs. 15,000/-  is not paid within 
same in the case         along with suspension    45 days then an 
with HSD also.           of sales and supplies    extension of 
                         of all products for 60   suspension for 
                         days in the second       another 30 days. 
                         instance.                If the fine is not 
                                                  paid even within 
                                                  the extended 
                                                  period, then the
1. If the explana-       3. Terminatin of         dealership will be
tion of the dealer       Dealership in            terminated.
is not satisfactory,     third instance.          2. Termination of
dealership is to be                               Dealership in 
terminated even in                                the second 
the first instance.                               instance.
2.If adulteration could 
not  be established 
despite stock 
variation was 
found, sales and 
supplies of all 
products will be 
suspended for 
15 days.
2. Short Deliver of Products : 
(Major offence)  If Weights & Measures  seals are tampered with 
Sales and supplies       1. Suspension of         1. Suspension of 
of all products is       sales and supplies       sales and supplies 
to be  suspended         of all products for      of all products for 
for 15 days.             15 days alongwith        30 days alongwith 
                         a fine of Rs. 2,000/-    a fine of Rs. 50,000/-
                         in the first             in the first 
                         instance.                instance.
                         2. In the second         2. In the second 
                         instance suspension      instance, for 
                         of sales and supplies    dealership is 
                         for 30 days alongwith    to be 
                         a fine of                terminated.
                         Rs. 5,000/-.
                         3. In the third 
                         instance,
                         dealership 
                         should be
                         terminated.
PUNISHMENTS              PUNISHMENTS              PUNISHMENTS 
EXISTING                 EXISTING                 EXISTING      
IN MDG 1982              IN MDG 1995              IN MDG 1998   
3.  Provision  of  unauthorised storage facility in case  of  detection  of 
storage of facilities not approved by the company and/or not in  accordance 
with Explosive approval : (Major Offence) 
Sales and supplies of all products to be suspended with immediate effect.
Not included            1. Suspension of         1. Suspension of 
                         sales and supplies       sales and supplies 
                         of all the products      of all the products 
                         for 15 days along        for 15 days along
                         with  a fine of          with a fine of 
                         Rs. 2,000/- in the       Rs. 20,000/- in the
                         first instance.          first instance.
                         2. In the second         2. In the second 
                         instance, suspension     instance, suspension 
                         of sales and supplies    of sales and supplies
                         for 30 days alongwith    for 30 days along
                         a fine of Rs. 5,000/-.   with a fine of 
                                                  Rs. 50,000/-
                         3. In the third          3. In the third 
                         instance, dealership     instance, suspens in 
                         to be terminated.        of sales and supplies 
                                                  for 45 days along 
                                                  with a fine of
                                                  Rs. 1 lakh.
4.  Not producing for Inspection Stock/Sales Registers at the time of  sur-
prise check (Major Offence)
1. Warning letter        In the first             1. Suspension of 
to be issued             instance, suitable       sales and supplies 
in the first             warning letter will      of all the products 
instance.                be issued and sub-       for 15 days along
                         sequent instances,       with a fine of 
                         sales and supplies       Rs. 20,000/- in 
                         of all products to       the first 
                         be suspended for         instance.
                         15 days etc.
2. Sales and                                      2. In the second
supplies of all                                   instance, suspension 
products is to                                    of sales and supplies 
be suspended                                      for 30 days along
for 15 days in                                    with a fine of 
the second                                        Rs. 50,000/-
instance.
                                                  3. In the third 
                                                  instance, 
                                                  suspension of 
                                                  sales and 
                                                  supplies for 
                                                  45 days along 
                                                  with a fine 
                                                  of Rs 1 lakh.
5. Unauthorised purchases/sales/exchange of MS/HSD etc. (Major Offence) 
Sales and supplies       1. Suspension of         1. Suspension of 
of all products is       sales and supplies       sales and supplies 
to be  suspended         of all products for      of all products for 
for 15 days.             30 days alongwith        30 days along
                         a fine of Rs. 5,000/-    with a fine of 
                         in the  first            Rs. 50,000/- in the
                         instance.                first instance.
                         2. Termination of        2. In the second 
                         dealership in the         instance, fine of 
                         second instance.         Rs. 1 lakh and 
                                                  suspension of  
                                                  sales and
                                                  supplies for 
                                                  45 days.
                                                  3. In the third,
                                                  dealership to 
                                                  be terminated.
LUBES: 
6. Established case of selling offspec Lubes, (Major Offence)
Sales and supplies       Suspension of sales      1. Suspension of 
of all products is       and supplies of all      sales  and supplies
to be suspended          products for 15 days     of all the products 
for 15 days.             alongwith a fine of      for 15 days along
                         Rs. 2,000/- in the       with a fine of 
                         first instance.          Rs. 20,000/- in the 
                                                  first instance.
                         In the second            2. In the second
                         instance, suspension     instance, suspension 
                         of sales and supplies    of sales and supplies 
                         for 30 days alongwith    for 30 days along
                         a fine of                with a fine of
                         Rs. 50,000/-.            Rs. 50,000/-
                         Dealership to be         3. In the third 
                         terminated in the        instance, dealership 
                         third instance.          to be terminated.
7. Unauthorised purchases/sales/exchange of Lubes etc. (Major Offence)  
Sales and supplies       1. Suspension of         1. Suspension of 
of all products is       sales and supplies       sales and supplies 
to be suspended          of all products for      of all the products 
for 15 days.             15 days alongwith        for 15 days along
                         a fine of Rs.5,000/-     with a fine of 
                         in the first             Rs. 20,000/- in the 
                         instance.                first instance.
                         2. Termination of        2. in the second
                         dealership in            instance, suspension 
                         the second               of sales and supplies 
                         instance.                for 30 days along
                                                  with a fine of
                                                  Rs. 50,000/-.
                
                                                  In the third instance
                                                  dealership to be
                                                  terminated.

PUNISHMENTS              PUNISHMENTS              PUNISHMENTS 
EXISTING                 EXISTING                 EXISTING
IN MDG 1982              IN MDG 1995              IN MDG 1998 
8. Non-availability of reference density at the time of inspection : 
Sales and supplies of all products to be suspended immediately, samples  to 
be drawn and sent for testing within 24 hrs. In case product meets specifi-
cation,  sales and  supplies of all products to be resumed with  a  warning 
letter (Major Offence). 
Density test             In case of               In case of 
was not                  product being            product being   
introduced.              off-spec                 off-spec:
Hence not 
applicable.
                         1. Fine of  Rs.          1. Fine of Rs. 
                         5,000/-  alongwith       50,000/- along with 
                         suspension of            suspension of  sales 
                         sales and supplies       and supplies of all 
                         of all products for      products for 30 days 
                         30 days in the           in the first 
                         first instance.          instance.
                         2. Termination of        2. Fine of Rs 1 lakh 
                         dealership in the        alongwith suspension 
                         second instance.         of sales  and supplies 
                                                  for 45 days.
                                                  3. Termination of 
                                                  dealership in 
                                                  third instance.
9. Mobile Lab Inspection : Clinical tests will be conducted even though the 
density is in order. In the event of Density passing but failing in  Clini-
cal test, (Major Offence)

Mobile Lab was           Sales/supplies to        Action to be taken 
not introduced.          be suspended after       by the Oil  Co. as            
Hence not                recording of tank        proposed for 
applicable.              dips/pump meter          established adulteration.
                         reading etc.             1. Sales and supplies 
                         concerned Oil Co.        are to be suspended
                         will have to replace     by Mobile Lab in 
                         the off-spec product     the event of failure
                         before sales             of sample in lab test.
                         are resumed.             2. SLC and concerned          
                                                  Oil Co. to be 
                                                  advised.   
                                                  (State Level 
                                                  Coordinators).
PUNISHMENTS              PUNISHMENTS              PUNISHMENTS 
EXISTING                 EXISTING                 EXISTING
IN MDG 1982              IN MDG 1995              IN MDG 1998 
MINOR OFFENCES:
1. Overcharging (Minor Offence)
Sales and supplies       1. Suspension of         1. Suspension of 
of all  products to      sales and supplies       sales and supplies 
be suspended             of all the products      of all the products  
for 15 days.             for 15 days along        for 15 days along 
                         with  a fine of          with  a fine of 
                         Rs. 2,000/- in           Rs. 20,000/- in 
                         the first instance.      the first instance.
                         2. In the second         2. In the second 
                         instance, suspension     instance, suspension 
                         of sales and supplies    of sales and supplies 
                         for 30 days along        for 30 days along 
                         with a fine of           with a fine of 
                         Rs. 5,000/-.             Rs. 50,000/-.
                         3. In the third          1. Suspension of 
                         instance,dealership      sales and  supplies 
                         to be terminated.        for 45  days along
                                                  with a fine of 
                                                  Rs. 1 lakh in the 
                                                  third instance.
2. Non observance of Govt. Regulations (Minor Offence). For non  observance 
of Govt. Regulation
Sales and supplies       Sales and supplies       1. Suspension of 
of all products to       of all products to       sales and supplies 
be suspended             be suspended for         of all products for 
for 15 days.             15 days.                 15 days alongwith 
                         a fine of 
                         Rs.20,000/- in 
                         the first 
                         instance.
                                                  2. In the second 
                                                  instance 
                                                  suspension 
                                                  of sales and 
                                                  supplies for 
                                                  30 days along 
                                                  with a fine of 
                                                  Rs. 50,000/-.
                                                  3. Suspension of 
                                                  sales and supplies 
                                                  for 45 days along 
                                                  with a fine of 
                                                  Rs. 1 lakh in 
                                                  the third 
                                                  instance.
3. Non Provision of Free Air, Drinking Water, Radiator Water, Toilet Facil-
ities, Telephone, First Aid, PUC (where applicable) at RO premises, follow-
ing action  to be taken (Minor Offence)
A warning letter         1. In case facilities    1. Suspension of 
to be issued to          are not provided         sales and supplies 
the concerned            within 60  days of       of all the products 
dealer and the           written advice, there    for 15 days along 
dealer should be         will be a fine of        with a fine of 
given time to provide    Rs. 2,000/- and 15       Rs. 20,000/- in 
the same. In case        days suspension of       the first 
the dealer fails to      sales and supplies       instance.
provide the facilities   of all  products.
within the stipulated 
time sales and
supplies of all 
products to  be 
suspended 
for 15 days.
                         2. If facilities are     2. In the second 
                         still not  provided,     instance, suspension 
                         a warning letter is      of sales and supplies 
                         to be issued along       for 30 days along 
                         with a fine of           with a fine of  
                         Rs. 5,000/- and          Rs. 50,000/-. 
                         30 days suspension 
                         of sales and supplies   
                         of all products.
                         3. Inspite of the        3. Suspension of      
                         above if the facilities  sales and supplies 
                         are still not provided   for 45 days along
                         the  dealership          with fine of 
                         should be                Rs. 1 lakh of  
                         terminated.              the third 
                                                  instance. 
        
4. Short Delivery of products.
If  W&M  seals are intact but deliveries are below tolerance  limit  (Minor 
Offence)
Sales and supplies       Sales and supplies       Sales and supplies
should be stopped        should be stopped        should stopped from 
from the Dispensing      from the Dispensing      the Dispensing Unit 
Unit till re-verific-    Unit till re-verific-    till re-verification  
ation is carried out     ation is carried out     is carried out by 
by Weights &             by Weights &             Weights 
Measures Dept.           Measures Dept.           & Measures Dept. 
If deliveries are proved to be below tolerance limit:
  
                                                  1. Suspension of 
                                                  sales and supplies 
                                                  of all products for 
                                                  15 days along
                                                  with a fine of 
                                                  Rs. 20,000/- in 
                                                  the first 
                                                  instance.
                                                  2. Suspension of 
                                                  sales and supplies 
                                                  for 30 days along 
                                                  with a fine of 
                                                  Rs. 50,000/- in 
                                                  the second 
                                                  instance.
                                                  3. Suspension of 
                                                  sales and supplies 
                                                  for 45 days along 
                                                  with a fine of 
                                                  Rs. 1 lakh in 
                                                  the third 
                                                  instance.
5.  RUDE BEHAVIOUR
Established cases of discourteous behaviour by dealers and/or his staff, non 
producing of complaints register, (Minor Offence):
This cause was           Penalty of Rs.2,000/-    1. Fine of Rs. 10,000/- 
not introduced.          for the first offence,   in the  first instance.
                         and Rs. 5,000/- for      2. Fine of Rs. 30,000/- 
                         every subsequent         in the second instance.
                         offence. Besides,        3. Suspension of 
                         a suitable  warning      sales and supplies 
                         letter will be issued    for 45 days along 
                         to the dealer by         with a fine of Rs. 1 
                         the concerned Oil Co.    lakh in the 
                         third instance.
6.  Established  cases of a issuance of fake PUC  certificates  by  dealers 
having PUC facilities (Minor Offence)
Not available.           Not available.           1. Suspension of 
                                                  sales and supplies 
                                                  of all the products 
                                                  for 15 days along 
                                                  with a fine of 
                                                  Rs. 20,000/- in 
                                                  the first 
                                                  instance.
                                                  2. In the second 
                                                  instance, 
                                                  suspension of 
                                                  sales and supplies 
                                                  for 30 days along 
                                                  with a fine of 
                                                  Rs. 50,000/-.
                                                  3. In the third 
                                                  instance, 
                                                  dealership to 
                                                  be terminated.
7.  Sale of LVI (Low Viscosity Index) Lubes from Retail Outlet  (Minor  Of-
fences)
If  the  dealer is found stocking/selling LVI Lubes at/through  the  Retail 
Outlet
If the explanation       1. Fine of Rs. 5,000/-   1. Suspension of 
of the dealer is         along with suspension    sales supplies of 
not satisfactory,        of sales and supplies    all the products for 
sales and supplies       of all products for      ples of all the 
of all products to be    15 days in the first     products for 15 
suspended for 15         instance.                days  along with 
days and the dealer                               a fine of Rs 20,000 
should be suitably                                in the first 
cautioned through                                 instance. 
a warning letter.
 
                         2. Termination of        2. In the second 
                         dealership in the        instance, suspension 
                         second instance.         of sales and  supplies 
                                                  for 30 days along 
                                                  with a fine of 
                                                  Rs. 50,000/-.
                                                  3. In the third 
                                                  instance, 
                                                  dealership to 
                                                  be terminated.
 
8. Overcharging in authorised selling prices of Lubes (Minor Offence)
Dealer to be advised to charge correct prices:
Sales and supplies       1. Suspension of         1. Suspension of
of all products to be    Sales and supplies       sales and supplies 
suspended for            of all products for      of all products for 
15 days.                 15 days along with       15 days along with 
                         a fine of  Rs. 2,000/-   a  fine of 
                         in the first             Rs.20,000/- in the 
                         instance.                first instance.
                         2. In the second         2. In the second 
                         instance, suspension     instance, suspension 
                         of sales and supplies    of sales and supplies 
                         for 30 days along with   for 30 days along with 
                         a fine of Rs. 5,000/-.   a fine of Rs. 50,000/-.
                         3. In the third          3. In the third 
                         instance, dealership     instance, dealership 
                         to be terminated.        to be terminated.
9. Sale  of Lubes through Non calibrated measures (Minor Offence)
Not included             1. Suspension of         1. Suspension of 
                         sales and supplies       sales and supplies 
                         of all products for      of all products for 
                         15 days along with       15 days along with 
                         a fine of Rs. 2,000/-    a fine of Rs.20,000/-
                         in the first             in the first 
                         instance.                instance.
                         2. In the second         2. In the second 
                         instance, suspension     instance, suspension 
                         of sales and supplies    of sales and supplies 
                         for 30 days along with   for 30 days along 
                         a fine of Rs. 5,000/-.   with a fine of 
                                                  Rs. 50,000/-.
                         3. In the third          3. In the third 
                         instance, dealership     instance, dealership
                         to be terminated.        to be terminated.
10.   Violation/Non   observance  of  Govt.   Regulations   and   operating 
guidelines/instructions if any, on sale and distribution of SKO.
For non observance  of Govt. Regulation. (Minor Offence)
Sales/Supplies of        Sales and supplies       Sales/supplies of 
SKO to be suspe-         to be suspended for      SKO to be suspended 
nded (if necessary       15 days, on each         (if necessary in  
in consultation with     occurrence.              consultation with 
local Civil Supplies                              local Civil Supplies 
Authorities)                                      Authorities).
Suspension of sales and 
supplies of SKO for 15 
days.
                                                  1. Suspension of 
                                                  sales and supplies 
                                                  of SKO for 30 days 
                                                  along with a fine of 
                                                  Rs. 50,000/- in the 
                                                  first instance.
                                                  2. In the second 
                                                  instance, suspension 
                                                  of sales and supplies 
                                                  for 45 days along 
                                                  with a fine of 
                                                  Rs. 1 lakh.
                                                  3. In the third 
                                                  instance, dealership 
                                                  to be terminated.

11. Overcharging (Minor Offence)
Dealer to be advised to charge correct price
Sales/Supplies of        1. In the first          1. Fine of Rs.50,000/-
SKO to be suspended      instance, sales and      along with suspension 
(if necessary in         supplies of all          of sales and supplies of 
consultation with        products to be           all products for 30 days
local Civil Supplies     suspended for 15         in the first instance.
Authorities) Suspension  days along with a 
of Sales and supplies    fine of Rs. 2,000/-. 
of SKO for 15 days.
                         2. In the second         2. In the second 
                         instance, sales and      instance, suspension 
                         supplies of all products of sales and supplies 
                         to be suspended for      for 45 days along with 
                         a period of 30 days      a fine of  Rs. 1 lakh.
                         along with a fine of 
                         Rs. 5,000/-. 
                         3. In the third          3. In the third  
                         instance, the            instance, dealership  
                         dealership  should       to be terminated.
                         be terminated.
12. Short Deliver (Minor Offence)
Sales/Supplies of        Sales/Supplies of SKO    Sales/Supplies of SKO 
SKO to be suspe-         to be suspended (if      to be suspended (if
nded (if necessary       necessary in consul-     necessary in consultation 
in consultation with     tation with local Civil  with local  Civil
local Civil Supplies     Supplies Authorities)    Supplied Authorities).
Authorities) Susp-       for 15 days
ension of sales and 
supplies of SKO 
for 15 days.
                
                                             1. Suspension of sales 
                                             and supplies of SKO 
                                             for 30 days along with 
                                             a fine of Rs.50,000/-
                                             in the first instance.
                                             2. In the second 
                                             instance, suspension 
                                             of sales and supplied 
                                             for 45 days along 
                                             with a fine of Rs. 1 lakh.
                                             3. In the third instance, 
                                             dealership to be 
                                             terminated.
     13.  Unauthorised  purchase/sales/exchange of SKO or any  product 
     which could be used as a substitute for this product.
Sales and supplies  1. Fine of Rs. 25,000/-  Unauthorised purchase/sale/ 
of all products     along with suspension    exchange of SKO or any
to be suspended     of sales and supplies    product which could 
for 15 days         of all products for      be used as a substitute for 
                    15 days in the first     this product or diversion or 
                    instance.                stock variation.
                                             Seek dealer's
                                             explanation within 7 days. 
                                             In case the explanation
                                             is not satisfactory :
                    2. Termination of        1. Fine of Rs. 50,000/-
                    dealership in the        along with suspension of
                    second instance.         sales and supplies of all
                                             products for 30 days in 
                                             the first instance.
                                             2. In the second instance, 
                                             suspension of sales 
                                             and supplies for 45 
                                             days along with a 
                                             fine of Rs. 1 lakh.
                                             3. Termination of dealership 
                                             in the third instance.
 


17.  The  final  report  of  Special Vigilance  Drive  from  20.10.1998  to 
2.11.1998  is also filed along with the affidavit which may also be  quoted 
as under :- 
  


     "FINAL  REPORT  ON  SPECIAL  VIGILANCE  DRIVE  FROM  29.10.98  TO 
     2.11.98. 
 


1. As directed by the Hon’ble Minister (P & NG), a Special Vigilance Drive was launched throughout the country from 29.10.98 to 2.11.98. Preside to the drive, a meeting of CMDs, Directors (Marketing) and Executive Directors (Vigilance) of Oil Companies, RLC’s and SLC’s was convened by Additional Secretary (MOP & NG) on 26.10.98 and the detailed action plan was given to them for conducting this Special Drive.

2. All Chief Secretaries and Police Chiefs of States and Union Territories were requested to provide necessary assistance in conducting the raids.

3. During the drive surprise checks/raids were conducted at Retail Outlets, LPG Distributorships, SKO Dealerships, Oil Company Terminal/Depots, LPG Bottling Plants, enroute checking of Tank Trucks and at unauthorised dumps. The drive was conducted in 50towns throughout the country.

4. Due to various court cases pending in various High Courts against the Marketing Discipline Guidelines, 1998, it was decided to take action against the erring Dealers/Distributors in line with the previous Marketing Discipline Guidelines (MDG 1995).

5. The salient features of the drive are as under:-

Retail Outlets

————–

     (a)  Total No. of ROs inspected         1364
     (b)  No. of cases of short delivery 
     detected                            323
     (c)  No. of cases of suspected 
     adulteration detected                68
     (excluding 8 sample failures)
     (d)  No. of cases of sample failures      29
     (e)  Non provision of air facility 
     despite warning                       1
     (f)  Non availability of 
     basic facilities:
     (i)  Free air                       158
     (ii) Water                           21
     (iii)Toilet facilities              209
     (iv) Complaint Book                 148
     (v)  First Aid Box                  127
     Action Taken
     ------------
 

1. Sales and supplies of all products were suspended in line with Marketing Discipline Guidelines (MDG), 1995 where product adulteration was suspected.

2. Delivery through dispensing pumps were suspended where short delivery was detected, till reverification.

3. Oil Companies were advised by SLC’s for issuing warning letters to the Dealers for providing the basic facilities.

4. State-wise list of irregularities detected and non-availabili ty of facilities is also enclosed as Annexure-I and II.

5. The details of sales and supplies suspended for suspected adulteration is as under :

     State/UT            IOC  BPC  HPC  IBP  Total
      
     Andhra Pradesh           5    1         6
     Assam               1                   1
     Bihar               1    1    5         7
     Delhi                    1              1
     Goa                      4    1         5
     Gujarat             5    1    1    3    10
     Haryana             1         1         2
     Karnatka            5    3    5    1    14
     Madhya Pradesh      4    3    3    1    11
     Maharashtra         4    3         2    9
     Nagaland            1                   1
     Orissa              1                   1
     Punjab              2    2    2    1    7
     Sikkim              1    1         1    3
     Tamilnadu           1    3    9    2    15
     Uttar Pradesh       2    1              3
     West Bengal              2              2
      
     Total               29   30   28   11   98
     II   LPG Distributorships:
     --------------------
     Total number of LPG Distributors
     inspected                               :    626
     Irregularities detected:
     Diversion of domestic LPG Cylinders     :    61862
     Defective cylinders noticed             :    2438
     Action Taken
    ------------
 

     1.  Action  in  line with MDG was taken against  the  erring  LPG  Distributors.
 


2. All the defective cylinders were sent back to the Bottling Plants for rectification.

3. State-wise details of irregularities detected is enclosed as Annexure-III.

III. SKO Wholesalers:

—————-

    No. of inspections carried out          :    430
     No. of cases where irregularities 
     were detected                           :    16
     No. of Dealers found not adhering 
     to upliftment schedule                  :    225
     Action Taken
     ------------
 

1. Sales and supplies were suspended for 15 days in line with MDG for irregularities detected.

2. Warning letters were issued to the Dealers for adhering to upliftment schedule.

3. A State-wise list of SKO/LDO Dealers where irregularities were detected is enclosed as Annexure-IV.

IV. Enroute checking of TTs

———————–

     Total number of TTs Checked        :    1289
     Number of irregularities detected  :    113
 


During the enroute checking of TTs, irregularities like improper sealing of TTs, improper fittings, non welding of domes and seal Nos. not tallying with invoice etc. were detected.

Action Taken:

————

The matter was reported to the concerned Oil Company Depots/Terminals for corrective action.

State-wise details of enroute checks carried out is enclosed as Annexure-V.

V. Checks at Terminals:

——————-

     No. of inspections carried out          :    110
     No. of irregularities detected          :    60
     No. of cases of improper/loose sealing  :    47
     No. of cases of over/under filling      :    12
     No. of cases of improper fitting        :    1
     Action Taken
     ------------
 

     All Location Incharge were advised to take corrective action. 
 


State-wise list of Terminal/Depots where raids were conducted and irregularities detected is enclosed as Annexure -VI.

VI. Checks at LPG Bottling Plants

—————————–

     No. of Bottling Plants inspected   :    40
     No. of cylinders checked           :    13420
     No. of defective cylinders found   :    701
     Percentage of defective cylinders  :    5.2%
     Action Taken
     ------------
     All  the defective cylinders were send back for  refilling/proper  sealing.  The  details of PLG Plants inspected and irregularities  detected    is enclosed as per Annexure-VII.    VII. Checks at unauthorised Dumps:-
     ----------------------------
     Total number of inspection 
     carried out                        :    13
     Irregularities detected            :    4
 


In all the cases, FIRs were registered. Details of raids carried out at Dumps is enclosed as Annexure-VIII.

To conclude, it can be observed from the SLC’s reports that more number of irregularities were detected wherever SLC’s were enthusiastic and fully committed for the cause of the drive. The enthusiasm evinced by SLC’s Maharashtra, Goa, Gujarat, Madhya Pradesh, Tamil Nadu, Karnataka, Andhra Pradesh, Bihar and Sikkim needs to be commended.

Sd/-

(M.S. Ramachandran)

Executive Director”

18. The reading of the above will lay down the principles which necessitated the framing of the guidelines of 1982, 1995 and 1998 respectivel.There is no challenge to the guidelines of 1982 though the challenge is made to 1995 guidelines along with 1998 guidelines in these two petitions.The purpose of framing the guidelines was to put an end to malpractice and remedy the breaches which were detected from time to time and are referred to in the vigilance report which has already been reproduced. It was considered imperative on the basis of the facts as enumerated above that the guidelines had to be framed to check malpractice and there is no arbitrary exercise of power. The State Machinery is provided ample discretion in the matter and clause 43 of the agreement vests in the Authorities powers to remedy breaches and there is no violation of the same. In Peerless General Finance and Investment Co. Ltd. and another Vs. Reserve Bank of India , the Supreme Court considered the powers of Reserve Bank of India in issuance of directions providing for manner in which the
deposits received by the residuary non-banking companies were to be deposited by them and manner in which such deposits are to be disclosed in their balance sheet or books of account and whether such directions were covered under Section 45-K(3) of the Reserve Bank of India Act. Paragraph 37, 68,72 and 73 read as follows:-

“37.Paragraph 5 of the directions relates to the minimum rate of return fixed at 10% per annum for a deposit with a maturity of 10 years. It is a matter of common knowledge that in the present times even the public sector corporations and banks and other financial and non-financial companies pay interest at much more higher rates ranging from 14 to 18%. Thus according to the above scheme the respondent companies and the other doing such business
can easily earn a profit of 4 to 5% on their investments. In case of a request of the depositors for repayment of the deposit before maturity then the amount payable by the company by way of nterest etc., shall be 2% less than what could have been ordinarily paid by the company by way of interest if the deposit had run the full comtractual period. However, the question of repay ment before maturity or after how many years will depend entirely on the terms and conditions of the contract of such deposit. Paragraph 12 of the directions of 1987 enjoins upon the company to sclosed as liabilities in its books of accounts and balance sheets the total amount of deposits received together with inter est, bonus, premium or other advantage,accrued or payable to the depositors. Under Clause (a) to the explanation to clause 3 of paragraph ‘6’ “Aggregate Amounts of Liabilities” shall mean total amount of deposits received together with interest, premium, bonus or other advantage by whatever name called, accrued on the amount of deposits according to the terms of contract. Thus the company is required to deposit or invest the aggregate amounts of its liabilities having accrued on the amount of deposits accord ing to the terms of contract. Without going into the figures shown in the various charts, it is clear that if the directions contained in paragraphs 6 and 12 of the directions of 1987 are to
be carried out, the companies are not left to utilise any amount of the deposits as working capital to meet the expenses. In our view the Reserve Bank is right in taking the stand that if these companies want to do their business, they should invest their own working capital and find such resources elsewhere with which the Reserve Bank has no concern. If we look at the Annual Report and Accounts of Pear less for the Years 1988, 1989 and 1990 it is clear that it had conducted its business following the impugned directions of 1987 and still had earned substantial profits in these Years. It is clear that Peerless is a company having estab lished as back as in 1932 and had substantial funds to invest the
entire amount of deposits and had met the expenses out of its accumulated profits of the past Years. This shows that the business can be run and profit can be earned even after complying with the impugned directions of 1987 issued by the Reserve Bank. It is not the concern of this court to find out as to whether actuarial method of accounting or any other method would be feasible or possible to adopt by the companies while carrying out the conditions contained in paragraphs 6 and 12 of the directions of 1987. The companies are free to adopt any mode of accounting permissible under the law but it is certain that they will have to follow the entire terms and conditions contained in the im pugned directions of 1987 including those contained in paras 6 and 12. It is not the function of the Court to amend and lay down
some other directions and the High Court was totally wrong in doing so. The function of the Court is not to advise in matters relating to financial and economic policies for which bodies like Reserve Bank are fully competent. The Court can only strike down some or entire directions issued by the Reserve Bank in case the Court is satisfied that the directions were wholly unreasonable or violative of any provisions of the Constitution or any statute. It would be hazardous and risky for the courts to treat anunknown path and should leave such task to the expert bodies. This court has repeatedly said that matters of economic policy ought to be left to the Government. While dealing with the validity of an order passed on September 30,1977 fixing a retail price of mustard oil not exceeding Rs. 10%- per kilogram in exercise of
powers conferred by Sec. 3 of the Essential Commodities Act, a Bench of 7 Judges of this Court in M/s. Prag Ice & Oil Mills Vs. Union of India and Nav Bharat Oil Mills Vs. Union of India :

“We have listened to long arguments directed at showing us that producers and sellers of oil in various parts of the country will suffer so that they would give up producing or dealing in mustard oil. It was urged that this would, quits naturally, have its repercussions on consumers for whom mustard oil will become even more scarce than ever ultimately. We do not think that it is the function of this Court or of any Court to sit in judgment over such matters of economic policy as must necessarily be left to the Government of the day to decide. Many of them, as a measure
of price fixation must necessarily be, are matters of prediction of ultimate results on which even experts can seriously err and doubtlessly differ. Courts can certainly not be expected to decide them without even the aid of experts.”

“68. Looking from operational pragmatism, the restrictions though apparently appears to be harsh in form, in its systematic work ing, it would inculcate discipline in the business management, ubserve public confidence in the ability of the company to honor the contractual liability and assure due repayment at maturity of the amount deposited together with interest etc. Without any impediment. In other words, the restrictions in paragraph 6 of the directions intended to elongate the twin purposes, viz. habit of thrift among the needy without unduly jeopardising the interest of the employees of the companies and the R.N.B.Cs. Working system itself in addition to safety and due payment of
depositor’s money. True as contended by Shri Chatterji that there arises corresponding obligation to pay higher amount of commission to its agents and the commitment should be kept performed and the confidence enthused in the agents. But it is the look out of the businessman. The absence of ceiling on the rate of commission would give choice between the company and its agents to a contract in this regard and has freedom to manage its business. The R.N.B.Cs. are free to incur such expenses and organise their business as they desire including payment of commission as they think expedient. But the subscribers/depositor liability, under no cicumstances, would be in jeopardy and the directions were designed to ensure that the interest of the subscribers/deposi tors is secured at all times, prescribing investment of an equal
sum to the total liability to the subscribers/depositors. Para graph 12 is only a bridge between the depositors and the promise held out and the contract executed in furtherance thereof as a monitoring my cardium to keep the heart in paragraph 6 functioning without any hiatus. It is settled law that regulation includes
total prohibition in a given case where the mischief to be remedied warrants total prohibition. Vide Narendra Kumar Vs. Union of India . But the directions do not do that but act as a siphon between the subcriber/depositor and the business itself. Therefore, they are neither palpably arbitrary nor unjust nor unfair. The mechanism evolved in the directions is foolproof, as directed by this court in first Peerless case, to secure the interest of the depositors as well capable to monitor the business management of every R.N.B.C. It also thereby, protects interest of the employees/field Staff
commission agent etc. as on permanent basis overcoming initial convulsions. It was intended, in the best possible manner, to subserve the interest of all without putting any prohibitions in the ability of a company to raise the deposit, even in the ab sence of any adequate paid up capital or reserve fund or such pre-commitment of the owner, to secure such deposits.”

“72. Para 19 of the directions empowers the RBI to extend time for compliance or to exempt a particular company or a class thereof from ail or any of the provisions, either generally or for a specified period subject to such conditions as may be imposed. Power to exempt would include the power to be exercised from time to time as exigencies warrant. An individual company or the class thereof has to place necessary and relevant material facts necessary and relevant material facts before the R.B.I. of the hardship and the need for relief. A criticism of arbitrariness or unreasonableness may not be a ground to undo what was conceived best in the public interest. What is best is not always
discernible. The wisdom of any choice may be disputed or condemned. Mere errors of Government are not subject to judicial re view. The legislative remedy may be ineffective to mitigate the evil or fail to achieve its purpose, but it is the price to be paid for the trial and error inherent in the economic legislative efforts to grapple with obstinate social issues. It is proper for interference in judicial review, only, when the directions, regulations or restrictions are palpably arbitrary, demonstrably irrelevant or discriminatory. Exercise of power then can be
declared to be void under Art. 13 of the Constitution. So long as the exercise of power is broadly within the zone of reasonableness, the Court would not substitute its judgment for that of legislation or its agent as to matters within their prudence and power. The Court does not supplement the feel of the experts by its own values.

73. It is settled law that so long as the power is traceable to the statute, mere omission to recite the provisions does not denude the power of the legislature or rule making authority to make the regulations, nor considered without authority or law. Sec. 114 of the Evidence Act draws s tatutory presumption that official acts are regularly performed and reached satisfac-

tion on consideration of relevant facts. The absence of reitera tion of objectives satisfaction in the preamble as of one under Sec. 45L does not denude the powers, the r.B.I. admittedly has under Sec. 45L, to justify the actions. though Sec. 45L was
neither expressly stated nor mentioned in the preamble of the directions of the required recitation of satisfaction of objec tive facts to issue the directions from the facts and circumstances it is demonstrated that the R.B.I had such satisfaction in its considerations of its power under Sec. 45L, when the directions were issued. Even otherwise Sec. 45K itself is sufficient to uphold the directions.”

19. The Court held in paragraph 73 as referred to above that so long as the power is traceable to the statute, mere omission to recite the provision does not denude the power of the legislature or rule making authority to make the regulations and as such the impugned directions were held to be within the powers of Reserve Bank of India to provide tardy, stable, identifiable and monitorable method of operations by Residuary Non-Banking Companies.

20. In the present case it is contended by the petitioners that no such power is provided in any of the statutes controlling the sale and distribution of petrol products but at the same time one does not have to look to the statutes particularly when the parties have chosen to enter into contractual obligations. The power has to be traced from the agreement executed between the parties. Clause 43 of the agreement clearly spells out that the dealer shall observe and perform all directions or rules given or made from time to time by the Corporation for the proper carrying on of the
dealership of the Corporation. Similarly, clause 56 provides more powers for action when there is a breach of any of the covenants and stipulations contained in the agreement and there is failure to remedy such breach with in the period of receipt of the notice by the Corporation in this regard.In the subsequent judgment between the same parties in Reserve Bank of India and others Vs. Peerless General Finance and Investment Company Ltd. and another , the Supreme Court further elaborated the law on the subject and reiterated the findings earlier recorded that the Reserve Bank was within its powers to issue direction and the same were not ultravirus the powers conferred on the bank by Section
45K of the Reserve Bank of India Act.

21. The learned counsel for the petitioners have not denied that directions could be issued provided the powers are vested in the authorities in terms of the Agreement entered into between the parties. Clause 43, it is contended, does not confer any such powers to impose major and minor penalties particularly when such action violates the rule of law and principles of natural justice as no opportunity is provided to the petitioners to show cause. This argument is misconceived as more drastic remedy such as termination is provided in the various statutes and the various causes of the
agreement such as clauses 43 and 56 provide ample powers in the respondents to frame the guidelines as have been framed in the present case. The read ing of the punishment as prescribed for major and minor penalties could not show that the explanation of the dealer is always called for and action is only taken when it is not found to be satisfactory. In appropriate cases the members of the petitioner association can also ask for a personal hearing and the same cannot be denied. The mere absence of the quantum of fines in various statutes will not make the agreement between the parties
redundant on the ground that no power is vested in the authorities to frame such guidelines. The guidelines of 1982 and 1995 have operated satisfactorily and no one came forward on an earlier occasion to impugn those guidelines as the basic purpose for framing of the guidelines was to check adulteration, provide better service to the customers, to check violation f environmental health and safety regulations.

22. The writ petitioner under Article 226 of the Constitution of India is an extra-ordinary remedy and cannot be used for enforcement of contractual disputes and remedies which can be resorted to on the basis of the agreement executed between the parties. Paragraph 67 of the agreement may be reproduced as under :-

“67. Any dispute or difference of any nature whatsoever or regarding any right, liability, act, omission or account of any of the parties hereto arising out of or in relation to this Agreement shall be referred to the sole arbitration of the Direction Marketing of the Corporation, or of some Officer of the Corporation who may be nominated by the Director Marketing. The Dealer will not be entitled to raise any objection to any such arbitrator on the ground that the arbitrator is an Officer of the Corporation or that he has to deal with the matters to which the contract relates or that in the course of his duties or differ ences. In the event of the arbitrator to whom the matter is originally referred being transferred or vacating his office or being unable to act for any reason the Director Marketing as aforesaid at the time of such transfer, vacation of office or inability to act, shall designate another person to act as arbi trator in accordance with the terms of the Agreement. Such person, shall be entitled to proceed with the reference from the
point at which it was left by his predecessor. It is also at term of this contract that no person other than the Director Marketing or a person nominated by such Director Marketing of the Corporation as aforesaid shall act as arbitrator here under. The award of the arbitrator so appointed shall be final, conclusive and binding on all parties to the Agreement, subject to the Provisions of the Arbitration Act, 1940, or any statutory modification of or re-enactment thereof and the rules made thereunder and for the time being in force shall apply to the arbitration proceed-

ings under this clause.”

23. The above provision clearly stipulates that in case there is any dispute or difference arising between the parties regarding any right, liability or in relation to the agreement shall be referred to arbitration. The petitioners are at liberty to take recourse to this remedy and cannot impugn the guidelines which admittedly are framed on the basis of the powers vested in the respondents by the agreement entered into between the parties and which are framed for public good.

24. For the aforesaid reasons there is no merit in the writ petitions. The same are, accordingly, dismissed. Rule is discharged. There will be no order as to costs.