JUDGMENT :

DIPANKAR DATTA, J.

1. Leave granted.

2. The appellant is one of multiple respondents in W. P. (C) No. 36 of 2017, W. P. (C) No. 38 of 2017 and W. P. (C) No. 59 of 2017, pending on the file of the High Court of Sikkim (hereafter ‘the High Court’, for short). Separate applications in the said three writ petitions were filed by the appellant seeking its deletion from the array of respondents. The appellant had pleaded in the said applications that, inter alia, a notification issued by it was under challenge in the writ petitions and that if, at all, such notification could be made a subject matter of challenge, the High Court of Bombay at Goa is the appropriate Court where remedy ought to be pursued. According to the appellant, a notification issued under a statute enacted by a State legislature cannot be subjected to judicial scrutiny within the jurisdiction of a high Court of a different State, more so when no cause of action has arisen within the jurisdiction of that high Court. It was further pleaded that since no part of the cause of action for invocation of the writ jurisdiction had arisen within the territorial limits of the High Court, the writ petitions ought not to proceed against the appellant. One other fact brought to the notice of the High Court by the appellant was that the same notification was under challenge in W.P. (C) No. 759/2017 instituted by Serenity Trades Private Limited before the High Court of Bombay at Goa and that such writ petition after admission was pending for final hearing. It was urged by the appellant that to avoid conflict of opinions, the writ petitioners could either independently challenge the notification before the High Court of Bombay at Goa or apply for intervention in W.P. (C) No. 759/2017.

3. The High Court, by a common judgment and order dated 6th June, 2018, has dismissed the three applications. These three appeals, by special leave, are directed against such judgment and order.

4. Since a common judgment and order is under challenge, we propose to decide these appeals by this common judgment and order.

5. Various notifications issued under the Central Goods and Services Tax Act, 2017 (hereafter ‘CGST Act’, for short) and the Integrated Goods and Services Tax Act, 2017 (hereafter ‘IGST Act’, for short) are under challenge in all the three writ petitions together with rate-notifications issued by the States of Goa, Maharashtra, Punjab and Sikkim. Inter alia, the challenge is to a notification stated to bear “No. 01/2017” dated 30th June, 2017 issued by the Government of Goa in exercise of power conferred by sub-section (1) of section 11 of the Goa Goods and Services Tax Act, 2017 (hereafter ‘GGST Act’, for short) levying tax @ 14% on “(L)ottery authorized by State Governments”. The writ petitioners have invoked the high prerogative writ jurisdiction of the High Court to seek a declaration that the impugned notification is unconstitutional and illegal.

6. The short question that arises for a decision on these appeals is, whether the High Court was justified in returning the finding that “at least a part of the cause of action has arisen within the jurisdiction of this Court” and premised on such a finding, to dismiss the applications.

7. Notice was issued by this Court on 12th November, 2018, after condonation of delay in presentation of the petitions for special leave to appeal.

8. None has appeared for the writ petitioners despite service of notice. We have heard counsel for the appellant and the Additional Solicitor General appearing for the Union of India as well as counsel for the other appearing parties.

9. For the purpose of a decision on these appeals, the petition averments in W. P. (C) No. 38 of 2017 may be noticed. A private limited company, “engaged in the business of purchase and sale of lottery tickets run, conducted and organized by the Government of Sikkim both within the State of Sikkim as well as outside the State”, is the writ petitioner. The petitioning company se