The advocates' arguments in this case primarily focus on the following points:

1. Legality of the Scheme: The appellants argue that the e-auction scheme implemented by the Coal India Ltd and its subsidiaries, including the CCL, was declared ultra vires the constitutional provisions, specifically Article 14, by the higher courts. They contend that the scheme was fundamentally unlawful and that any transactions conducted under it are void, thereby entitling the companies to refunds for excess payments made pursuant to an illegal scheme (!) .

2. Binding Nature of Supreme Court Decisions: The petitioners emphasize that the decisions and directions issued by the Supreme Court, especially those declaring the scheme ultra vires and ordering refunds, are law of the land and are binding on all courts and authorities. They argue that subsequent courts and authorities are obliged to follow these decisions and that failure to do so constitutes a breach of constitutional duty (!) (!) .

3. Maintenance of Writ Petitions: The advocates contend that the companies' claims are based on their contractual rights arising from transactions under the unlawful scheme, which are directly affected by the Court’s declaration of the scheme’s illegality. They assert that the writ petitions are maintainable because they involve the enforcement of fundamental rights and legal obligations, and are not barred by delay or latches, especially since the cause of action arose after the Supreme Court’s final judgment (!) (!) .

4. Principles of Equity and Fairness: They argue that the State and its instrumentalities should not rely on technicalities to deny legitimate claims of citizens, especially when those claims are supported by the law and judicial directions. The advocates emphasize that the State must act honestly and in good faith, and that technical defenses such as delay or disputed facts should not prevent the grant of just relief in cases involving public interest and fairness (!) (!) .

5. Parity and Equality: The petitioners maintain that once the law and directions of the Supreme Court are clear, all similarly situated parties should be treated equally. They argue that denying refunds based on procedural or technical grounds violates the constitutional guarantee of equality under Article 14, and that all companies in similar circumstances should be granted the same relief (!) (!) .

6. Rejection of Unjust Enrichment Defense: The advocates assert that the principle of unjust enrichment does not apply in these cases because the transactions are commercial and not statutory dues. They contend that the companies paid excess amounts under an unlawful scheme, and therefore, they are entitled to refunds without the defense of unjust enrichment being applicable (!) (!) .

7. Proper Court Jurisdiction and Decision-Making: They argue that the courts below failed to follow the binding legal principles laid down by the higher courts, particularly in not considering the Supreme Court’s final judgments. This oversight led to incorrect dismissals of the claims, and the appellate courts should have adhered to the law as established by the Supreme Court (!) (!) .

8. Technicalities and Good Faith: The advocates emphasize that the State and its agencies should not rely on procedural technicalities such as delay or dispute of facts to defeat legitimate claims. Instead, they should act in an honest and fair manner, especially when judicial decisions have clearly established the illegality of the scheme and the entitlement of the companies to refunds (!) .

These arguments collectively aim to establish that the companies are entitled to refunds for payments made under an unlawful scheme, that the courts failed to apply the binding directions of the Supreme Court, and that technical defenses should not bar the enforcement of lawful and judicially recognized rights.