JUDGMENT :

M. S. Sonak, J.

1. Heard learned counsel for the parties.

2. Rule. The Rule is made returnable forthwith at the request of and with the consent of the learned counsel for the parties. Even otherwise, there were orders already made for the disposal of these petitions at the stage of admission itself.

3. Learned counsel for the parties agree that common issues of law and fact arise in both these petitions and therefore, both these petitions can be disposed of by a common judgment and order by treating Writ Petition No.2290/2021 (F) as the lead petition.

4. The petitioners in both these petitions challenge the insistence on the part of the respondents that the petitioners furnish an undertaking concerning the payment of all taxes, interest, and penalty, in case the GST Council ultimately decides that Extra Neutral Alcohol (ENA) is a commodity covered under the Goods and Services Tax (GST) Law, as a precondition for the issuance of “C and F Forms” under the provisions of the Central Sales Tax Act, 1956 (CST Act) and Rules made thereunder.

5. The petitioners claim that they have fulfilled the necessary terms and conditions prescribed under the CST Act thereby entitling them to the