M. R. CALLA J.-, J. ( 1 ) THIS Special Civil Application under Article 226 of the Constitution of India has been filed against the order Annexure-E dated 11 July 1994 seeking a direction against the State Government to grant exemption to the petitioners in respect of the land bearing Survey No. 1488/3 Paiki under Section 20 of the Urban Land (Ceiling and Regulation) Act 1976 (the Act for short ). ( 2 ) THE land in question admeasuring 9 acres 6 gunthas is situated in the limits of the Municipal Corporation Jamnagar. According to the petitioner the land comprises of Survey No. 1488 and the petitioners claim to be the owners of the land admeasuring 2 acres 11 gunthas out of the said Survey Number. The petitioners entered into an agreement to sell the land owned by them with one Shri Jayantilal Hansraj Shah as the proposed promoter of Vijay Co-operating Housing Society. It is also alleged that at that time the Government had issued the guidelines dated 25th October 1979 under the Urban Land (Ceiling and Regulation) Rules 1976 (the Rules for short ). The petitioners had applied for exemption under Section 20 of the Act on 12th December 1980 and according to the petitioners this application dated 12th December 1980 was to be considered in accordance with the guidelines issued by the Government on 25th October 1979 While the application dated 12th December 1980 was pending on 16th January 1982 the guidelines earlier issued on 25th October 1979 had been cancelled and the application for exemption moved by the petitioners under Section 20 of the Act was rejected on 27th September 1982 This order of rejection of the Application under Section 20 of the Act passed by the State Government on 27th September 1982 was challenged before this Court in Special Civil Application No. 4636 of 1982. On 10 August 1987 when Special Civil Application No. 4632 of 1982 came up for hearing the learned Counsel appearing on behalf of the Government made a statement that The petitioners application under Section 20 will be decided after giving them an opportunity of hearing in view of the decision of this Court in the case of Nirmalaben vs. State of Gujarat 25 (1) GLR 322. ( 3 ) ACCORDINGLY Special Civil Application No. 4636 of 1982 was allowed and the Rule was made absolute. ( 3 ) ACCORDINGLY Special Civil Application No. 4636 of 1982 was allowed and the Rule was made absolute. The State of Gujarat however took the matter to the Supreme Court and the Special Leave to Appeal relating to the order passed in the said Special Civil application No. 4636 of 1982 and other identical matters were decided by the Supreme Court on 10th March 1988 and the Supreme Court passed the order as under : heard learned Counsel for the parties. The Special Leave Petitions are dismissed subject to the observation that when the matter goes before the State Government for a fresh disposal the decision of the Division Bench of the Gujarat High Court in Nirmalaben Manilal Doshi and Ors. vs. State of Gujarat i. e. 1984 (1) Gujarat Law Reporter p. 322 should be the basis for disposal. After the aforesaid order of the Supreme Court passed way back on 10th March 1988 the Government has now passed the order on 11 July 1994 under Section 20 (1) of the Act whereby the application for exemption has been rejected and it is this order dated 11th July 1994 which is impugned in the present Special Civil Application. ( 4 ) IT may be pointed out at the very threshold that according to the Supreme Courts order dated 10 March 1988 the matter was to be decided on the basis of the Division Bench decision of this Court rendered in Nirmalabens case (supra) which was decided on 16th September 1983 by the Division Bench. However at the time when the Supreme Court passed the order on 10th March 1988 the Division Bench decision in Nirmalabens case (supra) was holding the field but later on Nirmalabens case was considered by the Full Bench of this Court which decided the controversy on 28 October 1988 after fully considering the Division Bench decision rendered in Nirmalabens ease (supra ). ( 5 ) SECTION 20 of the Act is reproduced as under :section 20 : (1) Notwithstanding anything contained in any of the foregoing provisions of this Chapter - (a) where any person holds vacant land in excess of the ceiling limit and the State Government is satisfied either on its own motion or otherwise that having regard to the location of such land the purpose for which such land is being or is proposed to be used and such other relevant factors as the circumstances of the ease may require it is necessary or expedient in the public interest so to so that Government may by order exempt subject to such conditions if any as may be specified in the order such vacant land from the provisions of this Chapter : (b) where any person holds vacant land in excess of the ceiling limit and the State Government either on its own motion or otherwise is satisfied that the application of the provisions of this Chapter would cause undue hardship to such person that Government may by order exempt subject to such conditions if any as may be specified in the order such vacant land from the provisions of this Chapter : provided that no order under this clause shall be made unless the reasons for doing so are recorded in writing. (2) If at any time the State Government is satisfied that any of the conditions subject to which any exemption under clause (a) or clause (b) of sub-section (1) is granted is not complied with by any person it shall be competent for the State Government to withdraw by order such exemption after giving a reasonable opportunity to such person for making a representation against the proposed withdrawal and there upon the provisions of this Chapter shall apply accordingly. A plain reading of Section 20 (1) which deals with the question of considering the application for exemption shows that if the Government is satisfied having regard to the location of such land the purpose for which such land is being or is proposed to be used and such other relevant factors as the circumstances of the case may require it is necessary or expedient in the public interest so to do that Government may by order exempt subject to such conditions if any as may he specified in the order such vacant land from the provisions of this Chapter and the proviso under Section 20 (1) shows that no order of exemption is to be passed unless the reasons for doing so are recorded in writing. Sub-section (2) of Section 20 provides that in case the exemption once granted is sought to be withdrawn a reasonable opportunity has to be afforded against the proposed withdrawal. Thus on the plain reading of this Section the reasonable opportunity is provided in case the exemption is sought to be withdrawn after it is granted Whether the exemption is to be granted or not depends upon the satisfaction of the Government with regard to the grounds mentioned under sub-section (1) of Section 20 of the Act If the Government is not satisfied about the availability or existence of the grounds mentioned in sub-section (1) of Section 20 of the Act it may decline to grant the exemption and for that purpose in the Section no opportunity as such has been provided. Thus the opportunity has been provided under sub-section (2) and under sub-section (1) of Section 20 of the Act the only provision is for satisfaction with regard to the grounds mentioned in sub-section (1) for the purpose of granting the exemption. The question of opportunity before rejecting an application for exemption has therefore been a subject-matter of debate before this Court and therefore Nirmalabens case (supra) was to govern the rights of the parties at the time when the order was passed by the Supreme Court on 10th March 1988 Now when this very question has been considered by the Full Bench of this Court and Nirmalabens case (supra) has also been considered therein the ratio of the decision of the Full Bench has to be considered and Mr. G. N. Desai learned Counsel appearing for the petitioners has drawn my attention to paragraph 14 of the decision of the Full Bench. The Full Bench has held that while dealing with an application under Section 20 (1) it is for the State Government to decide having regard to the facts and circumstances of each case whether a personal hearing or opportunity to make written representation on the matters likely to be used against the applicant should be given or not before disposing of the exemption application on merits against the concerned party unless the application is ex-facie not maintainable in law. The Full Bench has observed as under we do not subscribe to the argument that in each case the party seeking exemption is entitled to an audience or personal hearing before his application is decided against him. We do not read the observations in Nirmalabens case to lay down a rule of universal application that in all cases arising under Section 20 (1) of the Act regardless of the nature of the dispute the State Government is bound to give a personal hearing to the applicant before rejecting his application. A careful reading of the observations made in paragraph 3 of he judgment would show that the emphasis of the Court was on the complex nature of the issues to be tackled by the Government while exercising power or performing duty under Section 20 of the Act. That is why after speaking about the complex nature of the issues likely to arise before the State Government the Division Bench of this Court proceeded to observe : it is therefore in the fitness of the things that the Government should ordinarily hear the application if the Government is prima facie and ex-parte inclined to take a view that the exemption was not to be granted. The words ordinarily hear the applicant go to show that the Court did not intend to lay down any hard and last rule of universal application that in all the eases for exemption under Section 29 (1) of the Act the State Government was under an obligation to give an audience to the concerned party before rejecting his application. ( 6 ) MR. ( 6 ) MR. Desai learned Counsel appearing for the petitioners being fully alive and aware of the principle laid down by the Full Bench on this aspect of the matter submitted that here was a case of complex nature inasmuch as the Government was to decide as to whether the applications moved under Section 20 by the petitioners on 12th December 1980 were to be decided on the basis of the guidelines which had been issued on 25th October 1979 and which were operative on the date when the applications were moved or they were to be decided on the basis of the guidelines which had been issued later on because the guidelines dated 25th October 1979 had been cancelled on 16th January 1982 It has been pointed out on behalf of the petitioners that now the impugned rejection of the application under Section 20 of the Act is based on the guidelines which have been issued on 30th March 1984 It has been argued that this is a complex issue as to whether the guidelines of 25th October 1979 should have been the basis for deciding the application under Section 20 or the guidelines which were in force at the time when the orders were passed. It was also submitted that the very fact that on 10th August 1987 when the statement was made by the learned Counsel appearing for the respondent that the application under Section 20 will be decided after giving them an opportunity of hearing in view of the decision of this Court in the case of Nirmalaben (supra) that is the decision of the Division Bench that itself shows that according to the Government the opportunity was to be given. A perusal of the order dated 10th August 1987 shows that a statement was made by the learned Counsel on behalf of the Government on the basis of his understanding of the decision rendered by the Division Bench in Nirmalabens case (supra) but the Full Bench decision was rendered in October 1988 i. e. after the order dated 10th March 1988 passed by the Supreme Court and the guidelines dated 30th March 1984 had already been issued by the Government during the pendency of the first inning of the litigation i. e. even before the order dated 10th August 1987 was passed in Special Civil Application No. 4636 of 1982. Therefore in the first instance to me it does not appear to be a complex issue as to whether the guidelines which had been issued on 25th October 1979 should have been followed or the guidelines which had been issued later on and whereas it is not at all a complicated question there was no question of the opportunity in accordance with law laid down in the Full Bench decision. ( 7 ) BE that as it may the next submission which has been made on behalf of the petitioner is that the opportunity was granted to some of the members and the same was not granted to the petitioners. For that purpose my attention was invited to the averments made in the body of the Special Civil Application in paragraphs 24 and 25. As against the bald averments verified to be true to the best of the deponents knowledge the impugned order shows that the application for exemption was fixed for personal hearing before the Government in the proceedings under Section 20 not only once but on four different dates i. e. 15th March 1994 11 April 1994 2 May 1994 and 2nd June 1994 and thereafter it has been recorded that the application is decided on the basis of the guidelines dated 30th March 1984 as the guidelines dated 25th October 1979 had been cancelled earlier on 16th January 1982 The learned Counsel for the petitioners has raised a dispute that the petitioners were not given any notice for personal hearing. This bald statement does not withstand the contents of the impugned order in which it is mentioned that the matter was fixed for personal hearing on several dates. The dispute as against the contents of the order on factual aspects of the matter cannot be entertained more particularly when in the very first paragraph of the impugned order the reference has been made to the application moved under Section 20 of the Act on 12th December 1980 by the petitioners and to the first rejection of the application under Section 20 dated 27th September 1982 Thus the opportunity of personal hearing appears to have been granted before passing the order under Section 20 (1) of the Act. If the petitioners have failed to avail the same they have to thank themselves. If the petitioners have failed to avail the same they have to thank themselves. Even the averments which have been made in the body of the Special Civil Application on this aspect of the matter are not supported in the affidavit on the basis of the personal knowledge but it has been stated that it is true to the best of the knowledge. Thus I am of the considered opinion in this case that the opportunity has been granted to the petitioner and in case they have failed to avail the same no grievance on this aspect of the matter can be entertained. ( 8 ) AT this stage Mr. Desai learned Counsel for the petitioners has also submitted that even if it is held that the opportunity had been granted to the petitioners the order rejecting the application under Section 20 passed by the Government on 11th July 1994 was bad on merits because it had been passed on the basis of the guidelines which had been issued in the year 1984 whereas the petitioners had moved the application on 12th December 1980 and the same was to be decided on the basis of the guidelines which had been issued by the Government on 25th October 1979 because the exemption application had been moved keeping in view the guidelines dated 25th October 1979 Mr. Desai also relied upon the principle of Promissory Estoppel under Section 115 of the Indian Evidence Act and Legitimate Expectation. It may be straightway observed that the basic grounds and the foundation source for considering the applications under Section 20 are the grounds and factors mentioned in the Section itself. The guidelines are issued only to give effect to the provisions of the Act to advance the object of the Act and the provisions contained in the main Act. It may be straightway observed that the basic grounds and the foundation source for considering the applications under Section 20 are the grounds and factors mentioned in the Section itself. The guidelines are issued only to give effect to the provisions of the Act to advance the object of the Act and the provisions contained in the main Act. In such matters when the statute provides definite grounds for granting exemption the guidelines may be issued by the Government in accordance with the policy looking to the conditions which are available at that particular point of time and there cannot be any estoppel against the Government to revise its policy and change the guidelines from time to time and further the guidelines which have been issued in 1984 by the Government have not been assailed before me to be ultra vires or inconsistent with any of the provisions of the Act nor it is the case of the petitioners that the guidelines issued in 1984 on the basis of which the application for exemption was decided against them are in any way defeasible to the purpose and object of the Act or that it runs counter to any of the grounds mentioned in Section 20 for the purpose of deciding the question of exemption. In this view of the matter when the guidelines which had been issued in 1979 had already been cancelled in 1982 and new guidelines have been issued in the year 1984 the guidelines issued in 1984 could not be put in oblivion by the State Government; the Government could not have still acted upon the guidelines which had been issued in 1979. In such matters the argument that the applications under Section 20 are to be decided only on the basis of the guidelines available at the time of making application is neither available nor it is tenable and the same cannot be accepted This argument is also therefore rejected. ( 9 ) I do not find any substance in this Special Civil Application and the same is hereby dismissed. There shall be no order as to costs. Petition Dismissed. .