Judgment

K. RAMASWAMY, J.

(1) THESE writ petitions under Article 32 raise common question of law arising from same set of facts between the same parties though for different consignments. Hence they are disposed of by common judgment. The petitioner seeks writ of mandamus or any appropriate directions that the component/parts of ball bearings imported from foreign supplier M/s Impex Matel Lucka, Warszawa (Poland) are liable to excise duty prevalent as on 20/02/1989 and to release the goods on payment thereof or in the alternative to declare Section 15(l)(a) ultra vires Articles 14, 19(l)(g), 21, 265 and 300-A of the Constitution. The facts are that the petitioner placed in January-February 1988 an order with the Indian agent of the foreign supplier M/s Impex Matel Lucka, Warszawa, to supply ball bearings and irrevocable letters of credit were opened on 13/07/1988 for Rs. 13,07,830.00. The foreign supplier shipped the goods in M/s Stefan Czarniecki under bill of lading No. 9 and invoice No. 06/222/71154 dated 31/12/1988. The ship arrived on 20/02/1989 at Madras port and was ready to discharge the cargo. It delivered the import manifest under No. 1 16 on the even