Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2025 Supreme(Online)(Kar) 38548

THE HIGH COURT OF KARNATAKA
Vibhu Bakhru, CJ, C.M. Poonacha, J
Karnataka Industrial Area Development Board – Appellant
Versus
Lightsquare Designs Pvt Ltd – Respondent
WA No. 530 of 2025 | WA No. 510 of 2025 | WA No. 511 of 2025 | WA No. 512 of 2025 | WA No. 513 of 2025 | WA No. 514 of 2025 | WA No. 518 of 2025 | WA No. 521 of 2025 | WA No. 524 of 2025 | WA No. 525 of 2025 | WA No. 527 of 2025 | WA No. 528 of 2025 | WA No. 534 of 2025 | WA No. 544 of 2025 | WA No. 545 of 2025 | WA No. 731 of 2025 | WA No. 734 of 2025 | WA No. 751 of 2025 | WA No. 785 of 2025 | WA No. 792 of 2025 | WA No. 797 of 2025 | WA No. 809 of 2025 | WA No. 812 of 2025 | WA No. 918 of 2025

Advocates:
For the Appellants/Petitioners: B.B. Patil
For the Respondents: Shivaprasad Shantanagoudar, Namitha Mahesh, K.S. Harish

Statutory body recommendations are binding on implementing entities. A state authority cannot disregard these mandates based on alleged quota violations without presenting empirical evidence to substantiate that the specific thresholds established under industrial policy have been exceeded.

Headnote:(A) Industrial Facilitation Act - Section 11 - Binding nature of committee recommendations - Industrial policy regarding land allocation quotas for micro, small, and medium enterprises.

(B) Administrative Law - State instrumentality - Obligation to act transparently and fairly - Evidentiary burden - An entity must provide material evidence to substantiate claims that committee-recommended allocations exceed specified policy quotas.

(C) Appellate Jurisdiction - Scope - Appeals are not intended to allow parties to bypass statutory mandates without presenting evidence previously available but not produced. (Paras 4, 7, 8, 9, 10)

Facts of the case:
The board filed multiple appeals against an order mandating the implementation of land allocation recommendations issued by a district-level clearance committee. The board contended that these recommendations violated the 15% land reservation quota prescribed for specific enterprise categories under the prevailing industrial policy.

Findings of Court:
The court observed that the recommendations of the committee were statutorily binding. The board failed to produce sufficient material evidence to establish that the challenged allocations exceeded the 15% quota or that the board lacked necessary resources. The court further noted that the board’s own representative was a member of the decision-making committee, weakening the claim of procedural impropriety.

Issues: Whether the implementation of committee-driven land allocation recommendations is mandatory, and whether the primary entity can disregard such recommendations based on unverified assertions of policy violations.

Ratio Decidendi: The court held that committee recommendations are binding on the implementing authority. Furthermore, the burden of proof to demonstrate a violation of policy-mandated quotas rests solely on the authority challenging the recommendations. Without empirical evidence of a quota breach, an entity cannot unilaterally disregard statutory committee directives.

Result: Appeals disposed of with the clarification that the judgment shall not serve as a precedent precluding the board from challenging future allocations if they are substantiated by evidence of policy non-compliance.

Table of Content
1. statutory obligations of kiadb to comply with binding recommendations of the dlswcc under section 11 of the karnataka industries (facilitation act) 2002. (Para 1 , 2 , 3 , 4)
2. the burden of proof lies on the state instrumentality to provide evidence if asserting non-compliance with policy quotas for land allocation. (Para 5 , 6 , 7 , 8 , 9 , 10)
3. administrative bodies must challenge binding committee recommendations through proper legal channels rather than unilaterally ignoring them. (Para 11 , 12 , 13 , 14)

WRIT APPEAL NO. 530/2025 (GM-KIADB)

C/W

WRIT APPEAL NO. 510/2025, WRIT APPEAL NO. 511/ 2025,

WRIT APPEAL NO. 512/2025, WRIT APPEAL NO. 513/2025,

WRIT APPEAL NO. 514/2025, WRIT APPEAL NO. 518/2025,

WRIT APPEAL NO. 521/2025, WRIT APPEAL NO. 524/2025,

WRIT APPEAL NO. 525/2025, WRIT APPEAL NO. 527/2025,

WRIT APPEAL NO. 528/2025, WRIT APPEAL NO. 534/2025,

WRIT APPEAL NO. 544/2025, WRIT APPEAL NO. 545 /2025,

WRIT APPEAL NO. 731/2025, WRIT APPEAL NO. 734/2025,

WRIT APPEAL NO. 751/2025, WRIT APPEAL NO. 785/2025,

WRIT APPEAL NO. 792/2025, WRIT APPEAL NO. 797/2025,

WRIT APPEAL NO. 809/2025, WRIT APPEAL NO. 812/2025,

WRIT APPEAL NO. 918/2025 (GM-KIADB)

IN WA No. 530/2025

BETWEEN:

1. THE KARNATAKA INDUSTRIAL

AREA DEVELOPMENT BOARD

#49, 4TH AND 5TH FLOOR, EAST WING

KHANIJA BHAVAN

RACE COURSE ROAD

BENGALURU - 560 001.

REPRESENTED BY ITS

CHIEF EXECUTIVE OFFICER AND

EXECUTIVE MEMBER.

...APPELLANT

(BY SRI B.B. PATIL, ADVOCATE)

AND:

1. M/S LIGHTSQUARE DESIGNS PVT LTD.,

REP. BY ITS DIRECTOR

MR.YASHAWANT MEHTA

AGED ABOUT 46 YEARS

NO.81/1. MTB MAHAMEERU

RICHMOND ROAD

BANGALORE SOUTH - 560 025.

2. THE STATE OF KARNATAKA

REPRESENTED BY ITS

PRINCIPAL SECRETARY

COMMERCE AND INDUSTRIES DEPARTMENT

M. S. BUILDING

BENGALURU - 560 001.

...RESPONDENTS

(BY SRI SHIVAPRASAD SHANTANAGOUDAR, ADVOCATE FOR R-1 &

SMT. NAMITHA MAHESH, AGA FOR R-2)

IN WA NO. 510/2025

BETWEEN:

1. THE KARNATAKA INDUSTRIAL AREA

DEVELOPMENT BOARD

#49, 4TH & 5TH FLOOR, EAST WING

KHANIJA BHAVAN

RACE COURSE ROAD

BENGALURU - 560 001.

REPRESENTED BY ITS

CHIEF EXECUTIVE OFFICER.

...APPELLANT

(BY SRI B. B. PATIL, ADVOCATE)

AND:

1. M/S TANGLE OAKS

REP. BY ITS PROPRIETOR

SMT. LEELAVATHI M.,

AGED ABOUT 75 YEARS

PLOT NO.07, DREAM MEADOWS

NEAR RYAN INTERNATIONAL SCHOOL

BROOKFIELD, KUNDALAHALLI

BANGALORE - 560 037.

2. THE STATE OF KARNATAKA

REPRESENTED BY ITS

PRINCIPAL SECRETARY

COMMERCE AND INDUSTRIES DEPARTMENT

M. S. BUILDING,

BENGALURU - 560 025.

...RESPONDENTS

(BY SRI SHIVAPRASAD SHANTANAGOUDAR, ADVOCATE

FOR R-1 &

SMT. NAMITHA MAHESH, AGA FOR R-2)

IN WA NO. 511/2025

BETWEEN:

1. THE KARNATAKA INDUSTRIAL AREA

DEVELOPMENT BOARD

#49, 4TH & 5TH FLOOR, EAST WING

KHANIJA BHAVAN

RACE COURSE ROAD

BENGALURU - 560 001.

REPRESENTED BY ITS

CHIEF EXECUTIVE OFFICER.

...APPELLANT

(BY SRI B.B. PATIL, ADVOCATE)

AND:

1. M/S TRILLIANE ENTERPRISES PVT LTD.

REP. BY ITS DIRECTOR

MR. YASHAWANTH MEHTA

AGED ABOUT 47 YEARS

NO.81/1 RICHMOND ROAD

BANGALORE - 560 025.

2. THE STATE OF KARNATAKA

REPRESENTED BY ITS

PRINCIPAL SECRETARY

COMMERCE AND INDUSTRIES DEPARTMENT

M. S. BUILDING

BENGALURU - 560 025.

...RESPONDENTS

(BY SRI SHIVAPRASAD SHANTANAGOUDAR, ADVOCATE

FOR R-1 &

SRI K.S. HARISH, GOVERNMENT ADVOCATE FOR R-2)

IN WA NO. 512/2025

BETWEEN:

1. THE KARNATAKA INDUSTRIAL AREA

DEVELOPMENT BOARD

#49, 4TH & 5TH FLOOR, EAST WING

KHANIJA BHAVAN, RACE COURSE ROAD

BENGALURU - 560 001.

REPRESENTED BY ITS

CHIEF EXECUTIVE OFFICER &

EXECUTIVE ENGINEER.

...APPELLANT

(BY SRI B.B. PATIL, ADVOCATE)

AND:

1. M/S MR IT PARK

REP. BY ITS PROPRIETOR

MISS ROSHINI L

AGED ABOUT 49 YEARS

NO.114, 5TH MAIN ROAD

1ST BLOCK, BANASHANKARI 3RD STAGE VTC

BANGALORE SOUTH - 560 058.

2. THE STATE OF KARNATAKA

REPRESENTED BY ITS

PRINCIPAL SECRETARY

COMMERCE AND INDUSTRIES DEPARTMENT

M. S. BUILDING

BENGALURU - 560 025.

...RESPONDENTS

(BY SRI SHIVAPRASAD SHANTANAGOUDAR, ADVOCATE

FOR R-1 &

SMT. NAMITHA MAHESH, AGA FOR R-2)

IN WA NO. 513/2025

BETWEEN:

1. THE KARNATAKA INDUSTRIAL AREA

DEVELOPMENT BOARD

#49, 4TH & 5TH FLOOR, EAST WING

KHANIJA BHAVAN, RACE COURSE ROAD

BENGALURU - 560 001.

REPRESENTED BY ITS

CHIEF EXECUTIVE OFFICER.

...APPELLANT

(BY SRI B.B. PATIL, ADVOCATE)

AND:

1. M

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