S. R. NAYAK, J. ( 1 ) IN all these writ petitions, the petitioners are the companies, registered under the Companies Act and manufacturers of liquors situated in the states of Karnataka and Maharashtra. They export liquor to the State of andhra Pradesh, through the importer, namely, the Andhra Pradesh Beverages corporation Limited, Hyderabad. The said Corporation is also a Government company registered under the provisions of the Companies Act. ( 2 ) IN these writ petitions, the petitioners have assailed the constitutional validity of sub-rules (2), (4) (5) and (6) of rule 10 of the A. P. Indian Liquor and foreign Liquor Rules, 1970 (for short the rules ) framed by the Government of andhra Pradesh, in exercise of the powers conferred by Section 72 of the A. P. Excise act, 1968 (for short the Act ). The petitioners have also sought for certain other reliefs, such as declaration that the action of the respondents in collecting the countervailing duty and import fee afresh for the second time for revalidating the import permit as arbitrary and illegal; revalidation proceedings in question are illegal and invalid and for consequential directions to the respondents to refund the monies collected from the petitioners towards the countervailing duty and import fee. ( 3 ) ALTHOUGH the above reliefs, in addition to the constitutional validity of sub-rules (2), (4), (5) and (6) of Rule 10 of the Rules, are sought in the writ petitions, sri R. Nagendra Naidu, learned Counsel appearing for the petitioners, restricted the charge to the constitutional validity of the sub-rules (2 ). (4), (5) and (6) of Rule 10 of the Rules only and he did not advance any argument as regards other reliefs sought in the writ petitions. ( 4 ) RULE 10 of the Rules reads:-"10. (1) The Indian Liquor or Foreign liquor covered by the import permit shall be brought to its destination within the period of validity and permit holder shall send the intimation of arrival of indian Liquor or Foreign Liquor to the excise Superintendent of the destination under Rule 7 of these rules and obtain acknowledgment. (1) The Indian Liquor or Foreign liquor covered by the import permit shall be brought to its destination within the period of validity and permit holder shall send the intimation of arrival of indian Liquor or Foreign Liquor to the excise Superintendent of the destination under Rule 7 of these rules and obtain acknowledgment. (2) Where it is not possible for the holder of the permit to import Indian Liquor or foreign Liquor within the validity period specified in the permit for reasons beyond the control of the permit holder, he shall apply to the authorised officer for extention of the period of validity of the permit three days in advance of the expiry of the validity in the said permit specifying the reasons necessitating such extension together with the unutilised import permit in original and a Certificate from the Officer of the Exporting distillery/brewery that no Indian Liquor beer has been despatched from the distillery/brewery against such import permit. (3) On receipt of application under sub-rule (2) the Excise Superintendent may, after such enquiry as he may consider necessary and, on being satisfied that indian Liquor Beer has not been brought against the said permit, extend the validity of the import permit for a reasonable period. (4) Where it is established that it is not possible to import Indian Liquor specified in the import permit for the reasons, beyond the control of the holder of the import permit, the authorised officer may issue revised import permit specifying the validity period by changing the brand, or Brewery distillery, as the case may be, against the countervailing duty and import fee already paid after collecting differential duty and import fee, if any, provided the application for such Revised import Permit is made by the holder of the permit three days in advance of the expiry of the validity of the import specifying the reasons necessitating such Revised Import Permit together with the unutilised Import Permit in original and a certificate to the effect from the officer of the Exporting distillery/brewery that no Indian Liquor beer has been despatched from the distillery/brewery against the said import permit. (5) Where the import of Indian Liquor/ beer is not made within the validity of the import permit or within the extended period of the permit under sub-rule (3), or Revised Import Permit obtained under Sub-Rule (4), the countervailing duty and the import fee paid shall accrue to the Government on expiry of the validity specified in the import permit. (6) The countervailing duty and the import fee once paid shall not be refunded in any case. " ( 5 ) THERE is no controversy and there cannot be any controversy that the liability to pay import fee and countervailing duty is placed on the importer and not on the exporter under Rule 10. It appears that when that is the statute position, the petitioners/exporters herein voluntarily and out of their volition have entered into agreements with the Andhra Pradesh beverages Corporation Limited, Hyderabad, which is the importer, whereby and whereunder, the petitioners have undertaken to pay the countervailing duty and the import fee payable by the importer. It is stated that import fees, and countervailing duties were paid in advance to the importer. The grievance of the petitioners is that if the goods supplied by the petitioners/ exporters reach the destination in the State of Andhra Pradesh beyond the date specified in the import permits and in the event of the prescribed authority, the authorised officer in the importing State, refusing to revive the import permits, changing the validity period, the excise authorities in the importing state demand the countervailing duty and import fee again from the importer in addition to the duty already paid by the importer, and in the process and as per the agreements entered into between the petitioner-exporters and the importer, the petitioners are liable to pay the import fees and the countervailing duties twice. The contention of the learned counsel for the petitioners is that the countervailing duty and the import fee could be levied only when import takes place and not otherwise. The contention of the learned counsel for the petitioners is that the countervailing duty and the import fee could be levied only when import takes place and not otherwise. In support of this contention the learned Counsel would draw our attention to Entry 51 of the List-II of the Seventh schedule and also the decisions of the supreme Court in the case of S. K. Pattanaik v. State of Orissa, 2000 (1) SCC 413 , and para 16 of the judgment of a Division Bench of this Court in Excise Superintendent v. Shalini Beer and Wines, 1991 (3) ALT 292 , and Para 12 of the judgment of a learned single Judge of this Court in Phipson and company Limited v. Excise Superintendent, 1991 (1) ALT 378 , and would maintain that no countervailing duty be imposed twice under any circumstance. From this assumed premise, the learned Counsel for the petitioners would further contend that the provisions contained in sub-rule (5) of the rule 10 providing forfeiture of the countervailing duty and the import fee, in the event of the importer import within the specified time or within the extended period of the permit that may be granted under sub-rule (3) or failing to secure Revised import Permit envisaged under sub-rule (4), are totally arbitrary unconstitutional and violative of Articles 14, 301 to 304 of the constitution. ( 6 ) WE do not think it necessary for us to review the constitutional validity of the impugned Rules, particularly at the behest of the petitioners herein. It is well settled that the constitutional validity of the statute would be taken up by the constitutional Courts only at the behest of the affected persons. A Division Bench of this Court to which one of us (S. R. Nayak, J.), was a member, in S. Bharat Kumar and others v. Government of Andhra Pradesh and others, 2000 (6) ALD 217 (DB), held at page 242. "the Supreme Court in Yadbapati v. State of AP. , (1992) Supp. (1) SCC 74, has opined that the Court would not enter into the constitutionality of a statutory provision unless its constitutionality has been specifically challenged in the pleading setting out relevant grounds. "the Supreme Court in Yadbapati v. State of AP. , (1992) Supp. (1) SCC 74, has opined that the Court would not enter into the constitutionality of a statutory provision unless its constitutionality has been specifically challenged in the pleading setting out relevant grounds. One who invokes the power of Constitutional Court to declare an enactment enacted by the competent legislature to be unconstitutional must be able to show not only that the statute is invalid on certain constitutional grounds but that he had sustained or is in immediate danger of sustaining some direct injury as the result of its enforcement, and not merely that he suffers in some indirect way in common with the people at large. If a party challenges a Legislation on the ground of contravention of Part-Ill of the constitution, then he must satisfy the court that some fundamental rights to which he can lay claim has been impaired or has been threatened by the impugned legislation. "therefore, the threshold question to be considered in whether the petitioners, herein are in any way affected by the provisions of the sub-rules (2) (4) (5) (6) of Rule 10 of the Rules. In our considered opinion the above noted sub-rules do not impose any liability on the petitioners/exporters to pay either import fee or countervailing duty. As stated above, the liability to pay import fee as well as countervailing duty is exclusively placed on the importer and not on the exporter. However, Mr. Naidu would contend that though that is the position under the Act and the Rules, since the liability placed on the importer under the impugned rules has been taken over by the petitioners in these cases, it cannot be said that the petitioners are not the aggrieved persons, and therefore, the writ petitions filed by them are maintainable. We do not agree with the learned Counsel. We would have appreciated the submission of the learned counsel, provided the petitioners herein were obliged in law to enter into agreements with the A. P Beverages Corporation Limited, the importer for taking over the liability of the latter to pay the import fees and the countervailing duty in performance of a legal obligation flowing from the Act or the Rules made thereunder. That is not the case at all. That is not the case at all. If the Act or the Rules framed thereunder do not oblige the persons like the petitioners herein to take over the responsibility of paying import fee and countervailing duty and nevertheless, the petitioners, in their wisdom and guided by business expediency and interest, and on their own free Will and volition, enter into agreements with the importer to pay the countervailing duty and import fee, the petitioners cannot be heard to say that they are aggrieved by the obligations following from the agreements voluntarily executed by them in favour of the importer corporation. Be that as it may, the grievance of the petitioners does not touch upon any public law element. ( 7 ) IN that view of the matter, there is no need for this Court to decide the constitutional vires of the impugned Rules at the behest of the petitioners who are, according to us, not the aggrieved persons for the impugned rules do not impose any obligation on them to pay either import fees or countervailing duties. ( 8 ) ACCORDINGLY, the writ petitions are dismissed as not maintainable. No costs.