ORDER :

R. Raghunandan Rao, J.

1. The petitioners in this batch of writ petitions are owners of contract carriage vehicles, stage carriage vehicles and goods vehicles of different categories registered with the road transport authorities in the State of Andhra Pradesh. The owners of such vehicles are required to pay motor vehicle tax under the provisions of the Andhra Pradesh Motor Vehicles Taxation Act, 1963 (for short 'the Act') read with Andhra Pradesh Motor Vehicles Taxation Rules, 1963 (for short 'the Rules').

2. Section 3 of the Act provides for levy of tax as the Government may, by notification, direct from time to time on every motor vehicle used or kept for use, in a public place in the State. Under these provisions, the owners of such vehicles were paying quarterly tax for the quarters ending 31st March of the year, 30th June of the year, 30th September of the year and 31st December of the year. In the event of the owner of such a vehicle taking a decision not to ply the vehicle for any particular quarter, the said owner has to intimate the appropriate authority, under Rule 12A of the Rules, before the commencement of the quarter for which tax is due, that the motor vehicle would not be used after expiry of the period for which taxes has already been paid.

3. It is the case of the petitioners, that they had paid motor vehicle tax for the quarter ending 31.03.2020 (Barring some of the petitioners). However, due to the notifications issued by the State Government and the Central Government, on account of the Covid-19 pandemic, the offices of the road transport authorities in the State were closed and the movement of the vehicles of the petitioners was banned in the State of Andhra Pradesh for a large part of the quarter ending on 30.06.2020. It is the case of the petitioners that on account of the sudden closure of the offices of the road transport authorities around 22nd of March, the petitioners were unable to inform the Road Transport Authorities, under Rule 12A, of their intention not to ply their vehicles for the next quarter.

4. The petitioners have now approached this Court, on the ground that, the Road Transport Authorities are demanding the petitioners to pay the road tax for the quarter ending 30.06.2020 and subsequent quarters on the ground that none of the petitioners had submitted their request, under Rule 12A of the Rules, within the time stipulated in Rule 12A.

5. The petitioners assail such demands on two grounds. Firstly, they could not convey the necessary requests under Rule 12A on account of the complete lockdown put into force from 22.03.2020 and as such, would be entitled to further periods of time to convey such request even after the expiry of the time granted under Rule 12A. The petitioners also contend that the provisions of Section 3 empower the State to levy motor vehicle tax only on such vehicles which are "used or kept for use in a public place" in the State and since the lock down regulations prohibited the plying of any of the vehicles owned by the petitioners, the Government would not have the power to levy tax for those quarters where there was a ban of plying of vehicles. It is contended that Rule 12A would not come into the picture at all in such circumstances.

6. Before adverting to the response of the State, it would also be necessary to notice certain other facts. In this batch of writ petitions, some of the petitioners have sought exemption of payment of motor vehicle tax not only for the quarter ending 30.06.2020 but also for the quarter ending 30.09.2020. Further, it has also been contended by the learned Government Pleader that some of the petitioners have not paid the motor vehicle tax for the quarter ending 31.03.2020 and as such, those petitioners who have not paid the motor vehicle tax for the quarter ending 31.03.2020 shall not be entitled to any further benefit of exemption for the quarters ending 30.06.2020 and 30.09.2020. In some cases the tax was paid for the quarter ending