1. This Writ Petition under Art.226 of the Constitution of India, challenges the Notice dated 9th January, 2025 issued under Section S.351(1A) of the Mumbai Municipal Corporation Act, 1888 ('BMC Act') and the Order dated 21st February, 2025 thereof issued by the Brihanmumbai Municipal Corporation ('BMC'), which the Petitioners contend are illegal, violative of Art.14, Art.19(1)(g), Art.21 and Art.300A of the Constitution of India.

2. BRIEF FACTS:
M/s. Modern Paint And Auto Corporation, Petitioner No.1 is a partnership firm and Petitioner Nos.2 and 3 being its partners, operate an auto workshop for M/s. Mercedes Auto Hangar. They assert that their premises constitute a tolerated structure existing prior to the datum line of 1st April, 1962, for non - residential structures, as supported by Tikka Sheets of Cadastral Survey (1935, 1952 and 1969) and BMC Assessment Records.

3. Mr. Navroz Servai, learned senior counsel for the Petitioners, argues that the BMC failed to provide a fair hearing and disregarded material evidence, including factory licenses valid until 31st December 2027. He contends the Notice is jurisdictionally defective, motivated by an ulterior motive.
3.1. Mr. Seervai,