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IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD
Nagesh Bheemapaka, J
Reddy’s Laboratories Limited – Appellant
Versus
Competition Commission of India – Respondent
WRIT PETITION No. 25689 OF 2024

High Courts should refrain from exercising writ jurisdiction under Article 226 to interfere with ongoing statutory inquiries at an intermediate stage. When a statute provides a comprehensive mechanism for adjudication and an appellate remedy, parties should exhaust those remedies rather than seek premature judicial intervention.

Headnote:(A) Competition Act, 2002 - Sections 3, 4, 15, 19, 26, 27 and 53A - Writ jurisdiction under Article 226 of the Constitution - Extraordinary jurisdiction not to be exercised against administrative/procedural orders at intermediate stages of inquiry - Principle of exhaustion of alternative remedies - Intervention at premature stage leads to fragmentation of proceedings - Delay in investigation does not automatically void proceedings in absence of specific prejudice or legislative consequence of nullification. (Paras 4, 5, 6, 7, 8, 15, 16, 17, 18, 31)

(B) Writ Petition - Maintainability - Challenge to procedural directions such as filing objections to investigation report or furnishing of financial statements is premature - No civil consequences or final adjudication at this stage - Courts must exercise restraint when statute provides for a complete adjudicatory and appellate mechanism. (Paras 5, 8, 14, 19, 21)

(C) Competition Law - Statutory Interpretation - Section 15 of the Act provides a curative mechanism protecting proceedings from being invalidated by reason of vacancy or defect in the composition of the regulatory body - Constitutional or statutory challenges regarding composition must be raised with promptitude and not reserved as tactical weapons. (Paras 24, 25)

Facts of the case:
A petition was filed challenging the directions issued by a regulatory body during an ongoing inquiry. The petitioner challenged the investigation report on grounds of delay, violation of procedures, and the lack of a judicial member in the regulatory body's composition. The petitioner also contested the demand for recent audited financial statements, arguing that any potential penalty should be linked to the period of the alleged contravention.

Findings of Court:
The court found that the impugned orders were merely procedural and directed towards ensuring a proper inquiry. It held that the statutory scheme provided sufficient safeguards and that the petitioner had an efficacious alternative remedy of appeal after the final order. The court also observed that the petitioner's delay-based contentions and constitutional challenges were either premature or lacked sufficient grounds for invocation of extraordinary writ jurisdiction.

Issues: Whether the High Court should entertain a writ petition against procedural orders passed during the investigation stage of a statutory inquiry, and whether alleged procedural irregularities in investigation warrant interference under Article 226.

Ratio Decidendi: High Courts should not exercise their extraordinary jurisdiction to interfere with ongoing statutory investigations that are at an intermediate stage, as the Act provides a complete mechanism for adjudication and appeal. Courts must respect the legislative intent of enabling authorities to function without fragmented interference, provided no fundamental rights are violated and no irreversible civil consequences have been imposed.

Result: Writ petition dismissed.