Punjab & Haryana High Court Quashes STA Order Denying Taxi Permit Renewal; Holds Delay in Payment of Fee Curable, Not Fatal
Case Name: Anand Moudgil v. State Transport Authority, UT Chandigarh & Others
Date of Judgment: October 31, 2025
Citation: LPA-2497-2025
Bench: Hon’ble Mr. Justice Harpreet Singh Brar and Hon’ble Mr. Justice Sudeepti Sharma
Held: The Punjab & Haryana High Court quashed the order of the State Transport Authority (STA), UT Chandigarh, refusing renewal of the appellant’s taxi permit on the ground of delay in fee payment. The Division Bench held that such procedural delay cannot nullify a substantive right when the permit holder had complied with all other statutory requirements. The Bench ruled that administrative authorities must act reasonably and that mere technicalities cannot defeat legitimate entitlements, particularly where no third-party rights are affected.
Summary: The appellant’s taxi permit was cancelled by the STA due to alleged non-payment of renewal fees within the prescribed time. The appellant argued that the payment delay was inadvertent and that he had subsequently cleared all dues before the authority’s order of rejection. The Single Judge had dismissed the writ petition, upholding the STA’s decision. On appeal, the Division Bench found that the STA failed to exercise discretion judiciously and treated a procedural lapse as an absolute bar, contrary to the purpose of the Motor Vehicles Act, 1988 and corresponding rules.
The Bench referred to Union of India v. Tulsiram Patel (1985) 3 SCC 398 and State of Punjab v. Bhag Singh (2004) 1 SCC 547, reiterating that procedural prescriptions must advance, not defeat, the cause of justice. It emphasized that administrative authorities must interpret regulatory timelines with fairness and proportionality, especially in renewal and licensing matters where livelihood is involved.
Decision: Allowing the appeal, the High Court set aside both the STA’s order dated 14.03.2024 and the Single Judge’s judgment. It directed the STA to renew the appellant’s taxi permit within four weeks, subject to verification of other statutory conditions and fee payment. The Court clarified that the renewal would relate back to the date of original expiry to avoid any break in service continuity.