JUDGMENT

Ajay Bhanot, J.

1. I have the pleasure of reading the opinion rendered by my learned Brother on the Bench. I am in respectful disagreement with the same. Calling for a counter affidavit does not require elaborate reasons. But in view of the lengthy and erudite opinion of my learned Brother, I am constrained with all humility to set out some reasons why calling for counter affidavits from the respondents is necessary to subserve the ends of justice in this case.

2. Heard Shri N. C. Rajvanshi, learned Senior Counsel assisted by Shri Vishesh Rajvanshi, learned counsel for the petitioner, Shri Sanjay Goswami, learned Additional Chief Standing Counsel for the Staterespondents and Shri Sumit Kakkar, learned counsel for the respondent no. 4Stock Holding Corporation of India Limited.

3. The opinion will be structured in the following sequence:

I. The stamp duty as a Levy and the U.P. EStamping Rules, 2013:

II. Facts: i. Agencies engaged in collection of stamp duty and their functions ii. Proposed agreement

III. Legal issues and analysis of facts in light of such legal perspectives : i. Public functions and concept of authorities ii. Public law and contracts iii. Fundamental rights i