ORDER : Jayant Patel, J. These appeals are directed against order dated 03/02/2011 passed by the Learned Single Judge in the respective writ petitions whereby, the Learned Single Judge for the reasons recorded in the order, quashed the order passed by the first respondent-authority and issued further directions. 2. The brief facts of the case are that in the year 2006, respondent applied for composition of tax under Section 15 r/w Rule 137 of the Karnataka Value Added Tax Act, 2003 [hereinafter, referred to as "the KVAT Act"]. The said application was processed and ultimately, on 20/12/2006, certificate came to be issued and a copy of the said certificate is at Annexure "A", produced in the writ petition. On 02/07/2010 roughly after a period of 3½ years, the first respondent issued show-cause notice under Section 39(1) of the Act, proposing to levy tax at the rate of 12.5%, for the assessment period of 2005-06, stating that the respondent was not involved in the activity of works contract and therefore, reassessment was to be made. On 10/09/2010, petitioner submitted reply to the show-cause notice and prayed to drop the notice. On 29/09/2010, the first respondent proceeded to pass the order whereby, the reassessment was made and the tax was assessed. The respondent herein challenged the said decision of the reassessment by the first respondent by filing writ petitions before this Court. Learned Single Judge found that as per the due payment made by the petitioner in W.P.Nos. 13172-73/2010, paving bricks are included in Entry-2 of Schedule-III and the liability to pay tax would be at the rate of 4% only and not 12.5% and therefore, the order for re-assessment including the tax of 12.5% were set-aside and consequently, allowed the writ petition. Under the circumstances, the appellant-State has preferred the present appeals. 3. We have heard Sri. K.M. Shivayogi Swamy, Learned Addl. Government Advocate appearing for appellants and Smt. Vani H., Learned Counsel appearing for respondent. 4. It was contended by Learned Addl. Government Advocate appearing on behalf of the appellant-State that as per the view taken by this Court in W.A.No.5798/2011 and connected matters decided on 23/03/2016, paving bricks/blocks are not included in Entry-2 of Schedule-IEI and therefore, the liability to pay tax will be at the rate of 12.5% and not 4% as held by Learned Single Judge. Government Advocate appearing on behalf of the appellant-State that as per the view taken by this Court in W.A.No.5798/2011 and connected matters decided on 23/03/2016, paving bricks/blocks are not included in Entry-2 of Schedule-IEI and therefore, the liability to pay tax will be at the rate of 12.5% and not 4% as held by Learned Single Judge. It has been submitted that in the present order of reassessment, the tax was proposed to be recovered at 12.5% and hence, the order of the Learned Single Judge deserves to be set-aside and the reassessment already made by the first appellant be maintained. 5. Whereas, Learned Counsel appearing for the respondent-the original petitioner, contended that merely because this Court has taken a view that liability to pay tax on paving bricks/blocks would be 4% to 12.5%, would not be sufficient to maintain the order of reassessment. It is submitted that respondent had opted for a scheme whereby, payment of tax was by way of composition as provided under Section 15 of the Act. The application was made for such purpose and the competent authority being satisfied about the availability of composition of tax had also issued certificate on 20/12/2006. As per Learned Counsel for respondent, unless and until the said certificate is cancelled, there was no question of reassessment to be made de hors the composition scheme. She also submitted that even if such certificate was to be cancelled, the opportunity of hearing was required to be given specifically on the aspect as to why the certificate should not be cancelled but no such notice has been given nor any opportunity whatsoever was given on such aspects. She therefore, submitted that the relief as prayed for in the petition for quashing of order of reassessment made by the authority ought to have been granted though it is a different matter that the Learned Single Judge has granted relief on the other aspects and the aspect of cancellation of the certificate was not considered by the Learned Single Judge. She submitted that even otherwise also, a pure question of law is as to whether, prior to the cancellation of the certificate any reassessment can be made or not. In the circumstances, she submitted that ultimate decision taken by the Learned Single Judge for cancellation of the reassessment order may not be interfered with. 6. She submitted that even otherwise also, a pure question of law is as to whether, prior to the cancellation of the certificate any reassessment can be made or not. In the circumstances, she submitted that ultimate decision taken by the Learned Single Judge for cancellation of the reassessment order may not be interfered with. 6. As such, if we consider the reasons recorded by the Learned Single Judge, it appears that the Learned Single Judge was guided by his own decision dated 17/01/2011 in W.P.Nos. 13172-73/2010 and since he found that the duty leviable was 4% on the paving bricks/blocks and not 12.5%, the impugned order of reassessment was quashed. 7. In our view, if the only aspect considered by the Learned Single Judge is to be considered by us in the present appeal, the order of the Learned Single Judge cannot be maintained since writ appeal against the decision dated 17/01/2011 in W.P.Nos. 13172-73/2010 are allowed and this Court has held that the Entry-2 of Schedule-Ill would not include paving bricks/blocks and consequently, the liability to pay tax will not be 4% but can be 12.5%. 8. However, in our view, the matter does not end there. There is substance in the contention raised by the Learned Counsel appearing for respondent that unless and until the certificate regarding composition of tax has been cancelled, whether reassessment could be made by the authority or not. 9. In order to appreciate the contention, we may consider the relevant statutory provision and the Rules. Section 15 of the KVAT Act provides for composition of tax. As we are concerned in the present matter, to the issue limited to sub-Section (1), we find it appropriate to reproduce Section 15(1) of the Act as under:- "15. 9. In order to appreciate the contention, we may consider the relevant statutory provision and the Rules. Section 15 of the KVAT Act provides for composition of tax. As we are concerned in the present matter, to the issue limited to sub-Section (1), we find it appropriate to reproduce Section 15(1) of the Act as under:- "15. Composition of tax (1) Subject to such conditions and in such circumstances as may be prescribed, any dealer other than a dealer who purchases or obtains goods from outside the State or from outside the territory of India, liable to pay tax as specified in Section 4 and.- (a) whose total turnover in a year does not exceed an amount as may be notified by the State Government which shall not exceed fifty lakh rupees, and who is not a dealer falling under clause (b) or (c) or (d) below; (b) who is a dealer executing works contracts; or (c) who is a hotelier, restaurateur, caterer or dealer running a sweetmeat stall or an ice cream parlour or bakery or any other class of dealers as may be notified by the Government; or (d) who is a mechanised crushing unit producing [granite or any other metals; may elect to pay in lieu of the net amount of tax payable by him under this Act by way of composition, an amount at such rate not exceeding five per cent on his total turnover or on the total consideration for the works contracts executed or not exceeding two lakh rupees for each crushing machine per annum as may be notified by the Government." (emphasis supplied) The aforesaid shows that if the conditions are satisfied as that of a dealer not having turnover exceeding Rs.50 lakhs or who is a dealer executing the works contract or who is a hotelier, caterer or any other class of dealers as may be notified by the Government or mechanised crushing unit producing granite or any other metals, the option is available to such dealer to elect to pay in lieu of the net amount of tax payable on the basis of 5% of his total turnover or total consideration of the works contract. As in the present case, the other contingencies for the eligibility are not to be considered, they need not be discussed, but in the present case, the status claimed by the respondent was as a works contractor, the tax at the rate of 5% was to be paid on the total consideration of the works contract. Rule 135 of the KVAT Rules, 2005 provides for the conditions of the scheme and Rule 136 would be relevant in the present case as the certificate has already been issued. Rule 137 reads as under:- "137. Issuing certificates:- The jurisdictional Local VAT officer or VAT sub-officer shall within a period of fifteen days from the date of receipt of Form VAT 1.- (1) if he considers that the Form VAT 1 submitted under Rule 136 is incorrect or incomplete or the dealer is ineligible for any other reason, after giving him the opportunity of showing cause in writing against rejection, issue a notice in Form VAT 9 informing the dealer that the Form VAT 1 is rejected and, where appropriate, demand any tax due; (2) if he is satisfied that the Form VAT 1 submitted under Rule 136 is correct and complete and within the time prescribed, issue a certificate in Form VAT 8 to the dealer; and (3) issue a further certified copy of the certificate where a certificate issued under clause (2) is lost or destroyed." The aforesaid shows that after submitting the application within the prescribed period, the jurisdictional local VAT Officer or the VAT Sub-Officer, if he is satisfied that the form of VAT submitted under Rule 136 is correct and complete, then within the time prescribed, he shall issue certificate in Form VAT-8 to the dealer. In the present case, such certificate has been issued and therefore, it would presuppose that the VAT Officer at the relevant point of time when the certificate was issued was satisfied about the correct and complete details submitted in the form under Rule 136. 10. Rule 145 of the Rules, which is relevant for the present case reads as under:- "145. 10. Rule 145 of the Rules, which is relevant for the present case reads as under:- "145. Cancellation of certificate:- The jurisdictional Local VAT officer or VAT sub-officer shall, on receipt of a final return filed by the dealer under Rule 143 and in the case of a dealer falling under Rule 142 or 144 on receipt of the dealer's final return or on his own motion, cancel such dealer s certificate and inform the dealer in Form VAT 11." The aforesaid shows that the jurisdictional Local VAT Officer or VAT Sub-Officer upon receipt of reply of the dealers, finally return or on his own motion may cancel such dealer's certificate and may inform to the dealer in Form VAT-11. As such, it can hardly be disputed that the cancellation of the certificate would result into civil consequence on the taxable liability on the assessee because as per Section 15 of the Act, the composition offered to the assessee at the rate of 5% on the turnover or total consideration is in lieu of all taxes. The moment the cancellation of the certificate is made, the consequence may arise for filing of regular return and payment of tax as per the respective entries of the schedule. Further, it may also attract the question of reassessment if the assessment is already made or otherwise. Under these circumstances, the power so provided for cancellation of certificate under Rule 145 has to be read with the observance of principles of natural justice inasmuch as it would be obligatory for the jurisdictional Local VAT Officer or the VAT Sub-Officer, to state the grounds and to call upon the assessee, who is holding certificate, as to why such certificate should not be cancelled. After the show-cause notice is issued and the opportunity is given to the dealer/assessee, the certificate may be cancelled, if such a case is made out. It is only thereafter, the intimation may be required to be given to the dealer in Form VAT-11. 11. We are inclined to read the observance of principles of natural justice into Rule 145 of the Rules as it is by now well-settled that if any order which would result in a civil consequence, is to be passed by any authority, such power has to be exercised by observance of principles of natural justice vide State of Orissa v. Dr. (Ms.) Binapani Dev, AIR 1967 SC 1269 . According to the Hon'ble Supreme Court in Mohinder Singh Gill v. The Chief Election Commissioner, AIR 1978 SC 851 , civil consequences implies infraction of not merely property of personal rights but of civil liberties, material deprivation and non-pecuniary damages. In other words, everything that adversely affects a citizen in a civil life inflicts civil consequences. 12. It is also well established proposition of law that an order passed in utter violation of the principles of natural justice is null and void even in administrative matters vide A.K. Kraipak v. Union of India, AIR 1970 SC 150 . Any violation of the principles of natural justice results in arbitrary exercise of power and therefore would be an infraction of Article 14 of the Constitution. It has been held in Union of India v. Tulasi Ram Patel, AIR 1985 SC 1416 that violation of rule of natural justice results in arbitrariness which is the same as discrimination and where discrimination is the result of state action, it is a violation of Article 14 thus, the principles of natural justice forms part and parcel of Article 14 of Constitution. Any non-compliance of Article 14 is a ground for seeking relief under Article 226 of the Constitution. Principles of natural justice in most cases are embedded in the Statute in order to ensure that there is no failure of justice of persons whose rights are going to be affected by the proposed action. But, even when they are not prescribed in a statute, it is necessary to read the said principles into the statute so as to bring it in conformity with Article 14 of the Constitution. Where the non-observance of natural justice results in civil consequences, it would per se cause in prejudice. In K.I. Shepherd v. Union of India, AIR 1988 SC 618, the Hon'ble Supreme Court has elucidated to the effect that natural justice now requires that persons liable to be directly affected by proposed administrative acts, decisions or proceedings be given adequate notice of what is proposed so that they may be in a position to (a) to make representations on their own behalf; (b) or to appear at a hearing or enquiry, if one is held; and (c) effectively to prepare their own case and to answer the case, if any, they have to meet. 13. 13. Thus, in the instant case, although the KVAT Act or Rules do not prescribe any provision for hearing a dealer prior to cancellation of the certificate issued by the authorities for payment of tax by way of composition under Section 15 of the Act, we are of the view that the principles of natural justice have to be read as part and parcel of Rule 145 of the Rules which deals with cancellation of certificate. 14. If the facts of the present case are further examined, it is not the case of the appellant-revenue that at any point of time, notice was issued under Rule 145 of the Rules, by the concerned officer for cancellation of certificate nor it is even the case of the appellant-revenue that the certificate has been cancelled and notice was given in Form VAT-11. 15. On the contrary, the record shows that it cannot be disputed by the Learned Counsel for the appellant that notice was issued for reassessment directly without cancellation of the certificate as per Annexure "C". If such is the situation that the certificate was not cancelled and the certificate remained as it was, then, the dealer would be entitled to continue to have the composition of tax in lieu of all taxable liability. It is only after the certificate is cancelled, the power may be available to the VAT Officer, to assess or reassess the liability to pay tax. In absence of cancellation, he will have power limited only to verify as to whether composition of tax as per the scheme of the Act has been paid or not. It need not be stated that in a case of composition of tax, the liability to pay tax as per respective entry for the respective schedule is not to be considered since it is in lieu of the same composition of tax is to be opted by the eligible dealer. 16. Under these circumstances, if the certificate is not cancelled and order of reassessment has been made, in our view, the same would run counter to the scheme of composition of tax as provided and conceived under Section 15 read with and the relevant Rules referred to above. 16. Under these circumstances, if the certificate is not cancelled and order of reassessment has been made, in our view, the same would run counter to the scheme of composition of tax as provided and conceived under Section 15 read with and the relevant Rules referred to above. Hence, we find that even if the reasons recorded by the Learned Single Judge will not hold good, in view of our decision in Writ Appeal No. 5798/2011 decided on 23/03/2016, the order of reassessment which is already quashed may not be good fully but the quashing of the order of reassessment can be continued with the further observations as may be made hereinafter. 17. In view of the above observations and discussions, following directions are given:- "(1) As the certificate issued under Rule 137 has not been cancelled, the dealer-respondent herein would be entitled to continue with the benefit under Section 15 of the Act on composition of tax. (2) It is only after the certificate is cancelled by exercise of the power under Rule 145 r/w the observations made by us herein above, the assessment or reassessment can be made in respect of the dealer, who has opted for composition of tax. Hence, the order for reassessment and ultimate direction given for quashment of such reassessment shall remain but with the observation that if a case is made out, it would be open to the appellate authority to initiate the proceedings for cancellation of the certificate already issued under Rule 137 and if such an action is initiated, rights and contentions of both sides shall remain open as may be available in law." 18. The order of the Learned Single Judge stands modified to the aforesaid extent. The appeals shall stand disposed of accordingly. 19. Considering the facts and circumstances of the case, there is no order as to costs. Writ Appeals are disposed of.