Writ jurisdiction under Article 226 is not maintainable when a party fails to exhaust efficacious alternative statutory remedies for challenging tax enforcement measures, particularly where the person has failed to cooperate with investigative proceedings and administrative summons.

JUDGMENT :

1. Instant writ petition is preferred by the writ petitioner for quashing DRC-22 dated 12.03.2026 instituted by respondent no. 3 and further quashing the order of sealing of four business premises along with detachment of bank account.

2. The writ petition is filed with the following prayer:

"It is, therefore, respectfully prayed that the Hon'ble Court may be pleased to call the record of the matter and allow the present writ petition by:-

i. Issuance of a Writ in the nature of Certiorari/ Mandamus for quashing the order of sealing the four business premises of the petitioner i.e. the head office and other additional places.

ii. Issuance of a writ in the nature of certiorari / mandamus for quashing the DRC-22 dated 12.03.2026 and directing the respondents for de-attachment of bank accounts attached totally in violation of the provisions of the act

iii. Issuance of writ in the nature of mandamus for giving the directions to the respondents for taking no coercive steps against the petitioner as petitioner are unable to appear before the authorities as every action of the respondents is above law or in contradiction to the law iv. Any other order which this Hon'ble Court deems just and proper in facts and circumstances of the case be also passed in favor of the petitioner."

3. Learned counsel appearing on behalf of the petitioner while placing reliance upon judgment in case of M/s. Armour Security (India) Ltd. Vs. Commissioner, CGST Delhi, East Commissionerate and Ors. reported as 2025 INSC 982 has submitted that pursuant to summons issued to the petitioner, if petitioner has failed to appear, then only a coercive action be taken against him that too to ensure his attendance, but business premises cannot be sealed, as coercive measure. He further submitted that at the most a show cause notice be served upon the petitioner and the concerned authority may require the petitioner to submit his explanation to the facts mentioned in show cause notice. He also submitted that mere issuance of summons is not sufficient for initiation of any coercive proceeding under the CGST Act. He further submitted that section 6(2)(b) of the Central GST Act provides that only after issuance of show cause notice, an adjudicatory proceedings commenced formally but not prior to said notice. He further submitted that section 67 of the CGST Act does not authorize the respondents to seize the premises and freeze the bank account, and same is just a case of unnecessary harassment. He also submitted that the petitioner has submitted detailed objections to the respondents but the respondents have not considered the objections and without considering them initiated an action. He also submitted that there is no other remedy except to approach this Hon'ble Court for de-sealing the premises and de-attaching the bank account.

4. Learned counsel has further raised serious objections about the proceedings instituted by the respondents and submitted that the entire proceedings are without any jurisdiction and attachment in such a case is just an abuse of authority by the respondents. He further submitted that the petitioner be given a liberty to operate from the premises after de-sealing the premises and the respondents may continue to seal the goods lying in the compound, but the entire