ORDER A.M. Sapre, J. 1. By filing this petition under Articles 226 and 227 of the Constitution of India, the petitioner has questioned the legality and validity of show cause notice dated October 31, 1991 (annexure P6) issued by the Sales Tax Officer, Circle 7, Indore. 2. The show cause notice which is sought to be quashed reads as under : ^^vki e/;izns'k lkekU; fodj vf/kfu;e] 1958 ds v/khu iath;u izdj.k vk;,uMh@7@40@2369@9 ds /kkjd gSA vkids }kjk fuEukuqlkj cdk;k jkf'k tek ugha djk;h xbZ gSA 1- fnukad 1-4-87 ls 31-3-88 izkarh; 1]78]480 vr% vki fnukad 12-11-91 dks le; 11 cts dk;kZy; fodj vf/kdkjh] o`&7 bUnkSj esa v/kkSgLrk{kjdrkZ ds le{k mifLFkr gksdj dkj.k Li"V djsa fd vkidk iath;u izek.k&i= vf/kfu;e dh /kkjk 1510Mh ds v/khu D;ksa u fujLr dj fn;k tkosA fu;r fnukad dks vuqifLFkr jgus dh fLFkfr esa izdj.k esa ,d i{kh; fu.kZ; fy;k tkosxkA** 3. As stated supra, it is this show cause notice which is directly challenged by the petitioner in this writ instead of submitting it by filing a reply. The short question, therefore that falls for consideration is whether any case is made out for quashing this show cause in exercise of my writ jurisdiction under Articles 226 and 227 of the Constitution of India ? 4. Heard Shri P.M. Choudhary, learned counsel for the petitioner and Shri P. Verma, learned Government Advocate for the respondent-State. 5. Having heard the learned counsel for the parties and having perused the record of the case, I find no substance in the writ and hence it has to be dismissed. 6. The challenge to any show cause notice issued by any authority in writ is always on very limited grounds and that too only on pure legal grounds. In other words, the court has to see in its writ jurisdiction whether such a show cause, could be issued by an authority under the Act ? Whether the authority has jurisdiction to issue such show cause ? Whether it is within limitation (if limitation is prescribed for its issuance) ? Whether it constitutes some grounds for taking action proposed in it ? The writ court is not at this stage called upon to travel beyond the allegations made in show cause nor the writ court can be converted in fact-finding body to examine the case of person (petitioner). Whether it constitutes some grounds for taking action proposed in it ? The writ court is not at this stage called upon to travel beyond the allegations made in show cause nor the writ court can be converted in fact-finding body to examine the case of person (petitioner). That is the jurisdiction of the authority issuing a show cause to examine the facts. The reason is that show cause notice never partakes the nature of any order which determines the rights of the person to whom it is issued but it only gives an intimation to the person concerned of the proposed action likely to be taken against him. The show cause is only to call upon the person to file reply to whatever is mentioned in the show cause and contest it before the issuing authority, inter alia, raising factual or/and legal objections with a prayer that no action proposed in the said show cause be taken against the person concerned. The authority then depending upon the grounds raised by the person concerned in the reply to show cause hold an inquiry and then pass orders either exonerating the person or holds him liable. Depending upon the nature of order and the Scheme of the Act in which such order is passed the person then challenge the order in appeal if the right of appeal is provided under the Act or may take recourse to any other remedy available in law. It is only in some cases where the show cause is per se without authority of law and does not disclose any cause of action, the person to whom the show cause is issued can seek its quashing directly in writ jurisdiction to prevent abuse of power sought to be exercised by the authority and quash the same in exercise of its extraordinary powers conferred under Articles 226 and 227 of the Constitution. In other words, normal rule is to file reply to show cause and contest it before the authority issuing the show cause. It is only in some exceptional cases where strong prima facie case on abstract legal issues and that too by mere perusal of show cause notice is made out then this Court step in and quash such notice at its threshold. 7. Perusal of show cause (annexure P6) would show that it says that since petitioner has not deposited a sum of Rs. 7. Perusal of show cause (annexure P6) would show that it says that since petitioner has not deposited a sum of Rs. 1,78,480 by way of sales tax under the provisions of the Madhya Pradesh General Sales Tax Act (since repealed) for the period April 1, 1987 to March 31, 1988 and hence why penal action for cancellation of their registration as contemplated under Section 15(10)(d) ibid be not taken. The petitioner is asked to appear before the authority (S.T.O. Circle 7, Indore) and file their reply to the show cause. 8. I fail to appreciate as to what is there for this writ court at this stage to quash such show cause. The petitioner has filed a writ which is full of only facts. In other words, the facts pleaded in the writ according to the petitioner would make out a case for quashing the show cause. I am afraid, that this Court cannot embark upon the inquiry in writ. The facts which the petitioner has pleaded in great detail showing that how and on what basis, the petitioner is not liable to pay the tax demanded has to come by way of reply to show cause. It is for the authority issuing a notice to examine those facts which the petitioner has pleaded in the petition and not for this Court while examining the legality of the show cause. What the authority would have done it, the petitioner wants this Court to do it. 9. While attacking the show cause, learned counsel for the petitioner urged that whatever allegations petitioner has made in the petition are not denied by the respondent in their return and hence this Court can examine the legality of show cause on admitted facts and quash it. I do not agree to this submission. This is a case where these facts which are pleaded in detail by the petitioner are meant for the authority who has issued the show cause. It is for the authority to apply his mind to these factual aspect detailed in petition and then decide whether the tax could be demanded from the petitioner for the period April 1, 1987 to March 31, 1988 and whether a case for cancellation of registration is made out ? It is for the authority to apply his mind to these factual aspect detailed in petition and then decide whether the tax could be demanded from the petitioner for the period April 1, 1987 to March 31, 1988 and whether a case for cancellation of registration is made out ? Once any finding is recorded after appreciating these facts by the authority one way or other then the Higher Court (either appellate or even writ court, as the case may be) is able to appreciate the grievance of the petitioner. 10. In my opinion this is not a case where a show cause can be quashed purely on any legal issue or jurisdictional issue by its mere reading. It is also not a case where this Court can quash the show cause on the ground of it having been issued in contravention of any section of the Sales Tax Act. It is also not a case where it an be quashed on the ground that the authority issuing did not have jurisdiction to issue it, nor it is a case where the same can be quashed on the ground of it being barred by limitation. 11. In view of aforesaid discussion, this Court though initially issued notice entertaining the writ but do not find any ground to quash the show cause on any of the jurisdictional grounds. As observed supra, all the efforts of the petitioner is to ask this Court to quash the impugned show cause on the basis of several factual grounds which this Court cannot undertake in its writ jurisdiction. It is therefore, not necessary for this Court to deal with several submissions made by the learned counsel for the petitioner. 12. Accordingly, this petition is dismissed. However, the petitioner is granted one month's time to file suitable reply to show cause and raise all factual as well as legal grounds in support of their case. The authority (S.T.O. Circle 7, Indore) after the reply is filed by the petitioner would give opportunity to the petitioner and will pass reasoned order meeting all the factual and legal objection raised by the petitioner. Since the matter is pending for quite a long, the respondent (S.T.O. Circle 7, Indore) would complete the proceedings within four months from the date of filing of objections/reply by the petitioner. No costs. Security amount, if deposited by the petitioner, be refunded. Since the matter is pending for quite a long, the respondent (S.T.O. Circle 7, Indore) would complete the proceedings within four months from the date of filing of objections/reply by the petitioner. No costs. Security amount, if deposited by the petitioner, be refunded. LATER ON After the judgment was laid on table, counsel for the petitioner made a submission that some of the points urged by him have not been considered in the judgment such as show cause notice for cancellation was wrongly issued to legal representatives of the deceased partner of the firm and that in the absence of any provision in the Act no recovery could be made and that no opportunity was given to legal representatives before enforcing the demand. Since I have already observed in para 11 of the judgment that all the arguments advanced by the petitioner need not be specifically dealt with in view of the fact that petitioner is granted an opportunity to raise all these objections before the authority by filing a reply. It is not necessary for me to give any finding on these arguments. Moreover these submissions are based on mixed questions of fact and law and hence they cannot be properly considered in writ at its threshold. That apart, no prejudice is caused to the petitioner in case if these objections are raised before the authority concerned. So far as challenge to the assessment orders and the revision orders on merits-is concerned, since no finding is recorded one way or other in regard to challenge to show cause notice the petitioner will always be at liberty to challenge the orders of assessment/revision at the later date as and when and if occasion so arises in any appropriate proceedings in accordance with law. 1 therefore refrain from examining its legality at this stage. The aforesaid observations will be treated to be a part of the judgment delivered by me today.