Pvr Inox Limited Vs State of Chhattisgarh (Chhattisgarh High Court)
Summary: Pvr Inox Limited filed a writ petition challenging a resolution passed by the Mayor-in-Council, Municipal Corporation, Raipur, on 10.04.2026. The resolution proposed increasing “Pradarshan Shulk” (Show Tax) for cinema theatres in shopping malls from ₹200 to ₹600 per show per screen. The petitioner also challenged the consequential demand notice dated 24.04.2026. It argued that the increase was arbitrary and excessive, contrary to the Chhattisgarh Municipal Corporation Act, 1956 and the constitutional scheme governing municipal taxation, and could not be implemented without State Government approval. During the proceedings, State counsel informed the Court that the State Government had refused approval for the resolution by an order dated 12.06.2026. The petitioner acknowledged that development. The High Court found that the resolution under challenge had not received the requisite approval and that the grievance concerning the resolution and consequential demand notice no longer survived for adjudication. It dismissed the writ petition as infructuous. The Court did not decide the petitioner’s objections to the proposed tax increase on their merits.
FULL TEXT OF THE JUDGMENT/ORDER OF CHHATTISGARH HIGH COURT
1. The present writ petition under Article 226 of the Constitution of India has been filed by the petitioner, inter alia, challenging the legality, validity and propriety of Resolution (Sankalp Patra) No. 13 dated 10.04.2026 passed by the Mayor-in-Council, Municipal Corporation, Raipur, whereby the rate of ‘Pradarshan Shulk’ (Show Tax) in respect of cinema theatres situated within shopping malls was enhanced from ₹200/- per show per screen to ₹600/- per show per screen. The petitioner has also challenged the consequential Demand Notice dated 24.04.2026 issued pursuant to the aforesaid resolution.
2. Learned counsel for the petitioner submits that the impugned resolution was challenged, inter alia, on the ground that the enhancement of ‘Pradarshan Shulk’ was arbitrary, excessive and contrary to the provisions of the Chhattisgarh Municipal Corporation Act, 1956 and the constitutional scheme governing municipal taxation. It was further contended that the impugned resolution could not have been acted upon without the requisite sanction/approval of the State Government.
3. Learned State counsel, however, submits that the grievance raised by the petitioner has subsequently been redressed. It is submitted that the State Government, upon consideration of the resolution/proposal dated 10.04.2026 passed by the Municipal Corporation, Raipur, has, vide order dated 12.06.2026, declined/refused to accord approval to the said resolution. It is, therefore, contended that the impugned resolution dated 10.04.2026 does not survive for implementation and, consequently, nothing remains to be adjudicated in the present writ petition.
4. Learned counsel for the petitioner, in view of the aforesaid subsequent development, submits that the State Government has refused to accord its approval/sanction to the resolution dated 10.04.2026 passed by the Municipal Corporation, Raipur.
5. Having heard learned counsel for the parties and having considered the subsequent development brought on record, this Court finds that the very resolution which is the subject matter of challenge in the present petition has not received the requisite approval/sanction of the State Government and the State Government, vide order dated 12.06.2026, has rejected/refused to accord approval to the said resolution.
6. In view of the aforesaid subsequent development, the grievance raised by the petitioner against Resolution (Sankalp Patra) No. 13 dated 10.04.2026 and the consequential Demand Notice dated 24.04.2026 no longer survives for adjudication.
7. Accordingly, nothing survives for adjudication in this petition.
8. As a result, the Writ Petition is dismissed being infructuous.
