JUDGMENT G. S. SINGHVI, J. - The petitioner has invoked jurisdiction of this Court under article 226 of the Constitution of India for quashing the assessment order annexure P-7 dated February 16, 2001 passed by the Assistant Excise and Taxation Commissioner (Inspection)-cum-Assessing Authority, Patiala, who has also been impleaded as a party in person (respondent No. 4), and the demand notice annexure P8 issued by the said respondent for payment of Rs. 98,47,230 as dues of tax for the assessment year 1997-98. It has also prayed for initiation of proceedings against respondent No. 4 under the Contempt of Courts Act, 1971. A perusal of the record shows that the petitioner is engaged in the business of manufacture of country liquor. It is registered as a dealer under the Punjab General Sales Tax Act, 1948 (for short, "the Act"). By an order dated October 31, 2000, respondent No. 3 framed the assessment for the year 1997-98 and created a demand of Rs. 98,50,561 by holding that glass bottles used as packing material/containers for country liquor constitute as an independent commodity which is liable to tax at the rate applicable to the goods specified in entry 23 of Schedule A of the Act. The petitioner challenged that order by filing C.W.P. No. 16301 of 2000 which was disposed of by this Court on December 21, 2000 in the following terms : "(i) The impugned order shall be treated inoperative and ineffective qua the petitioner. (ii) The representative of the petitioner shall appear before the Assessing Authority on December 26, 2000. (iii) After giving reasonable opportunity of hearing to him/her, the Assessing Authority may pass fresh assessment order keeping in view the various judicial pronouncements to which reference had been made by counsel for the parties during the course of hearing. (iv) While passing fresh order, the Assessing Authority shall consider all the points which may be raised by the representative of the petitioner." In compliance of the direction given by the court, the petitioner appeared before respondent No. 3 and submitted written arguments claiming that the glass bottles used as containers for sale of country liquor could not be treated as an independent commodity for the purpose of assessment. After considering the plea raised by the petitioner, respondent No. 4 passed the impugned order and issued the demand notice for payment of tax specified therein. After considering the plea raised by the petitioner, respondent No. 4 passed the impugned order and issued the demand notice for payment of tax specified therein. Shri Mohan Jain, learned counsel for the petitioner vehemently argued that the impugned order should be declared as void because it is ex facie contrary to the law laid down by this Court in Punjab Breweries Limited v. State of Punjab [1999] 112 STC 314 and is vitiated due to mala fides of respondent No. 4. He further argued that the decision of the Karnataka High Court in State of Karnataka v. Shaw Wallace and Co. Ltd. [1981] 48 STC 169 does not have any bearing on the issue of levy of tax of bottles at a higher rate under the Act and respondent No. 4 has committed a serious illegality by creating demand against the petitioner by relying on the said decision. At the hearing, we asked the learned counsel as to why the petitioner may not be relegated to the alternative remedy of appeal available under section 20 of the Act. Shri Jain responded to this query by arguing that article 226 does not contain any bar to the entertaining of a writ petition on the ground of availability of alternative remedy and in the peculiar facts of this case the court should entertain the writ petition and quash the impugned order and demand notice because respondent No. 4 has deliberately ignored the law laid down by this Court and passed the impugned order with the sole object of causing harm to the petitioner. We have given serious thought to the argument/submission of the learned counsel, but have not felt persuaded to agree with him. It is true that article 226 does not contain any limitation on the exercise of jurisdiction by the High Courts to issue directions, orders or writs in the nature of mandamus, certiorari, prohibition, habeas corpus and quo warranto, but in the last 50 years, the superior courts have evolved several rules of self-imposed limitations/restraints based on sound public policy for exercise of that jurisdiction. One of these rules is that the writ petition will not be entertained if an effective alternative remedy is available to the petitioner. One of these rules is that the writ petition will not be entertained if an effective alternative remedy is available to the petitioner. This rule is based on the principle that if the statute regulating rights and duties of the parties contains a machinery for resolution of the disputes, then the High Court would be loath to directly entertain a petition under article 226 of the Constitution of India. This rule has been applied with greater rigour in cases challenging levy and collection of taxes, cess, fee, etc. In Raleigh Investment Co. Ltd. v. Governor-General in Council [1947] 15 ITR 332 (PC); AIR 1947 PC 78, the rule of alternative remedy was invoked in a case arising out of a suit brought for a declaration that the assessment made by the Income-tax Officer was nullity. While declining to entertain the claim, Lord Uthwatt, J., declared the law in the following words : "........... In the provenance of tax where the Act provided for a complete machinery which enabled an assessee effectively to raise in the courts the question of validity of an assessment denied an alternative jurisdiction to the High Court to interfere." The proposition laid down in the aforementioned decision was approved by a three Judges Bench in Titaghur Paper Mills Co. Ltd. v. State of Orissa [1983] 53 STC 315 SC; AIR 1983 SC 603 . In that case, the appellant had challenged the order of assessment passed under the Orissa Sales Tax Act, 1947 by filing a petition under article 226 of the Constitution of India on the ground that the assessing authority did not have the jurisdiction to pass the order. The Orissa High Court dismissed the writ petition summarily. While upholding the decision of the High Court, their Lordships of the Supreme Court observed as under : "Under the Scheme of the Act, there is a hierarchy of authorities before which the petitioners can get adequate redress against the wrongful acts complained of. The petitioners have the right to prefer an appeal before the prescribed authority under sub-section (1) of section 23 of the Act. The petitioners have the right to prefer an appeal before the prescribed authority under sub-section (1) of section 23 of the Act. If the petitioners are dissatisfied with the decision in the appeal, they can prefer a further appeal to the Tribunal under sub-section (3) of section 23 of the Act, and then ask for a case to be stated upon a question of law for the opinion of the High Court under section 24 of the Act. The Act provides for a complete machinery to challenge an order of assessment, and the impugned orders of assessment can only be challenged by the mode prescribed by the Act and not by a petition under article 226 of the Constitution. It is now well-recognised that where a right or liability is created by a statute which gives a special remedy for enforcing it, the remedy provided by that statute only must be availed of. This rule was stated with great clarity by Willes, J., in Wolverhampton New Water Works Co. v. Hawkesford (1859) 6 CB (NS) 336 at. 356 in the following passage : 'There are three classes of cases in which a liability may be established founded upon statute. ................ But there is a third class, viz., where a liability not existing at common law is created by a statute which at the same time gives a special and particular remedy for enforcing it ....................... The remedy provided by the statute must be followed, and it is not competent to the party to pursue the course applicable to cases of the second class. The form given by the statute must be adopted and adhered to.' The rule laid down in this passage was approved by the House of Lords in Neville v. London Express Newspaper Ltd. [1919] AC 368 and has been reaffirmed by the Privy Council in Attorney-General of Trinidad and Tobago v. Gordon Grant & Co., [1935] AC 532 and Secretary of State v. Mask & Co. AIR 1940 PC 105. It has also been held to be equally applicable to enforcement of rights, and has been followed by this court throughout. AIR 1940 PC 105. It has also been held to be equally applicable to enforcement of rights, and has been followed by this court throughout. The High Court was therefore justified in dismissing the writ petitions in limine." In Assistant Collector of Central Excise, Chandan Nagar, West Bengal v. Dunlop India Ltd. AIR 1985 SC 330 , a three Judges Bench of the Supreme Court reiterated the rule of alternative remedy in the following words : "........ where the statute itself provided the petitioners with an efficacious alternative remedy by way of an appeal to the prescribed authority, a second appeal to the Tribunal and thereafter to have the case stated to the High Court, it was not for the High Court to exercise its extraordinary jurisdiction under article 226 of the Constitution ignoring as it were, the complete statutory machinery. That it has become necessary, even now, for us to repeat this admonition is indeed a matter of tragic concern to us. Article 226 is not meant to short circuit or circumvent statutory procedures. It is only where statutory remedies are entirely ill-suited to meet the demands of extraordinary situations, as for instance where the very vires of the statute is in question or where private or public wrongs are so inextricably mixed up, and the prevention of public injury and the vindication of public justice require it that recourse may be had to article 226 of the Constitution. But then the court must have good and sufficient reason to by-pass the alternative remedy provided by statute. Surely matters involving the revenue where statutory remedies are available are not such matters ...." In State of Goa v. Leukoplast (India) Ltd. [1997] 105 STC 318; (1997) 3 JT 322 , the Supreme Court reversed the order passed by the Goa Bench of the Bombay High Court vide which it had quashed the order of assessment passed under the Central Sales Tax Act. One of the grounds on which the Supreme Court upset the order of the High Court was petitioner's failure to avail the statutory alternative remedy. Their Lordships invoked the rule laid down in Titaghur Paper Mills Co. One of the grounds on which the Supreme Court upset the order of the High Court was petitioner's failure to avail the statutory alternative remedy. Their Lordships invoked the rule laid down in Titaghur Paper Mills Co. Ltd. v. State of Orissa [1983] 53 STC 315 (SC); AIR 1983 SC 603 and observed as under : "We are of the view that the assessee should not have been allowed to by-pass the statutory remedies where the questions of fact could have been properly agitated and ascertained." The rule of alternative remedy has also been invoked in the following recent decisions for declining relief to the petitioner. 1. Karnataka Chemical Industries v. Union of India (1999) 113 ELT 17 (SC). 2. Chanan Singh & Sons v. Collector of Central Excise (1999) 9 SCC 17 . 3. State of Himachal Pradesh v. Raja Mahendra Pal (1999) 4 SCC 43 . The argument of Shri Mohan Jain that the petitioner should not be non-suited on the ground of availability of alternative remedy because the impugned order is ex facie contrary to the decision of this Court, sounds attractive but lacks merit and deserves to be rejected. At this stage, it would be inappropriate for us to make any observation on the merits of the order under challenge because the same is likely to prejudice the cause of the parties, but after having gone through the detailed reasons assigned by respondent No. 4, we are prima facie of the opinion that the officer concerned cannot be accused of having deliberately ignored or violated the law laid down by this Court or having acted with malus animus against the petitioner. Rather, the impugned order shows that she has decided the matter after objectively considering the points raised by the petitioner. It is quite possible that the appellate authority and ultimately the High Court may not approve the reasons recorded by respondent No. 4, but that cannot be a ground for allowing the petitioner to by-pass the statutory remedy of appeal. We are also not impressed by the argument of Shri Jain that the remedy of appeal available to the petitioner is burdensome and, therefore, the court should directly entertain the petition, cannot be accepted in view of the law laid down by the Supreme Court in Anant Mills Co. We are also not impressed by the argument of Shri Jain that the remedy of appeal available to the petitioner is burdensome and, therefore, the court should directly entertain the petition, cannot be accepted in view of the law laid down by the Supreme Court in Anant Mills Co. Ltd. v. State of Gujarat AIR 1975 SC 1234 and Shyam Kishore v. Municipal Corporation of Delhi (1993) 1 SCC 22 . For the reasons mentioned above, the writ petition is dismissed with liberty to the petitioner to avail the statutory alternative remedy. However, looking to the nature of the case, we direct the appellate authority to decide the appeal of the petitioner within four months of its presentation. Writ petition dismissed.