JUDGMENT : Ujjal Bhuyan, J. 1. Heard Ms N Hawelia, learned counsel for the petitioner and Mr. B Sarma, learned Standing Counsel, Central Excise Department for respondent No. 2. 2. None has appeared for respondent No. 1, State Bank of India. 3. By filing this petition under Article 226 of the Constitution of India, petitioner seeks quashing of garnishee notices issued by respondent No. 2 to respondent No. 1 and seeks a direction to respondent No. 2 to allow payment of service tax dues in installments. 4. As would be evident from the above, matter relates to payment of outstanding service tax dues by the petitioner. 4.1. Petitioner is a company incorporated under the Companies Act, 1956, having its registered office at Guwahati. For the period from April, 2013 to September, 2016, though petitioner had submitted its service tax returns, because of financial constraints, it could not pay the service tax collected. According to the petitioner, total liability for the said period stood at Rs. 6,27,45,124.00. For realization of dues, respondent No. 2 issued notice to respondent No. 1 on 14.02.2017 and on subsequent dates under Section 87 (b) of the Finance Act, 1994 calling upon respondent No. 1 to pay to the credit of the Central Government the money held by respondent No. 1 in the bank account of petitioner being Bank Account No. 34890601572. 5. Petitioner had represented before respondent No. 2 to withdraw the garnishee notices and to allow the petitioner to operate such bank account. Further prayer was made to allow the petitioner to pay outstanding dues in installments. Respondent No. 2 informed the petitioner on 11.04.2017 that the garnishee notices could not be withdrawn. Regarding payment of dues on installments, it was stated that the matter was under consideration of the Commissioner. 6. Petitioner has stated that despite financial difficulties it had made payment of Rs. 24,00,000.00 on 05.01.2019 towards meeting the liabilities and thereafter a further amount of Rs. 1 lac on 21.01.2019. 7. Notwithstanding the same, respondent No. 2 had instructed the clients of the petitioner not to make payments to the petitioner in view of issuance of garnishee notices. 8. Faced with such a situation, present writ petition has been filed seeking the reliefs as indicated above. 9. This Court vide order dated 20.2.2019 had directed Mr. 1 lac on 21.01.2019. 7. Notwithstanding the same, respondent No. 2 had instructed the clients of the petitioner not to make payments to the petitioner in view of issuance of garnishee notices. 8. Faced with such a situation, present writ petition has been filed seeking the reliefs as indicated above. 9. This Court vide order dated 20.2.2019 had directed Mr. Sarma, learned counsel for respondent No. 2 to obtain instructions regarding prayer of the petitioner for payment of service tax dues in installments. In the meanwhile, an interim order was passed to the effect that no further coercive measures be taken against the petitioner. 10. Petitioner filed an interlocutory application being IA(Civil) No. 1064/2019 to quash subsequent notices issued pursuant to the garnishee notices. The subsequent notices were issued to different clients of the petitioner calling upon them to pay directly to the Central Government account as part amount covered by the garnishee notices. 11. This Court by order dated 08.04.2019 held that interim order passed on 20.02.2019 was holding the field. Therefore, the subsequent notices should not be acted upon until further order(s); besides clarifying that such notices would be subject to outcome of the writ petition. Relevant portion of the order dated 08.04.2019 is extracted hereunder:- "By filing this Interlocutory Application, petitioner seeks stay of notices issued to various entities by the Assistant Commissioner of Central Excise and GST Division-I, Guwahati under Section 87(b) of Chapter-IV of Finance Act, 1994 read with Section 174(2)(e) of the Central Goods and Service Taxes Act, 2017. Basic grievance of the petitioner is that the said notices have been issued without adjudicating the service tax liability of the petitioner and mechanical levy of interest Without adjudication, those notices could not have been issued. Levy of interest is not automatic. There is a wide range within which interest can be levied and this reflects exercise of discretionary powers by the adjudicating authority which was not exercised in the instant case. But the prime grievance expressed by the petitioner is that notwithstanding the interim protection extended by this Court to the petitioner on 20.02.2019, the said notices have been issued causing serious prejudice to the petitioner in the market. But the prime grievance expressed by the petitioner is that notwithstanding the interim protection extended by this Court to the petitioner on 20.02.2019, the said notices have been issued causing serious prejudice to the petitioner in the market. In support of her contention, learned counsel for the petitioner besides relying on the relevant provisions of the Finance Act, 1994 including Sections 73 and 75 thereof, has also placed reliance on a decision of the Karnataka High Court dated 29.04.2015 passed in WP (C) No. 14054/2015 (Ms. Prashanthi Vs. Union of India) to contend that recovery proceedings dehors adjudication and quantification of service tax dues by the registered service tax provider is not permissible. On the other hand, Mr. Sharma submits that these notices were issued prior to passing of the interim order dated 20.02.2019. After the interim order was passed by this Court, Department has not taken any coercive measures against the petitioner. He further submits that petitioner has huge amount of dues to be paid and despite having credit worthiness, petitioner has not cleared the dues. In such circumstances, question of payment by installment perhaps may not be permissible. Submissions made by learned counsel for the parties have been considered. Related WP(C) No. 1123/2019 has been filed assailing garnishee notice issued to the petitioner and further seeking direction to the petitioner's banker, i.e., State Bank of India to remit the money held by it into the account of the Assistant Commissioner or payment by installment." This Court on 20.02.2019 passed the following order:- "Petitioner is aggrieved by issuance of garnishee notices by the State Bank of India whereby bank account of the petitioner being account No. 34890601572 has been made inoperative for the petitioner for the purpose of appropriation of dues to be paid to the Commissionerate of Central Excise and Service Tax, Guwahati on account of service tax dues. Petitioner's request for allowing payment of the dues in installments is stated to be pending before the Commissioner since 2017. On the other hand, petitioner is not in a position to operate the said bank account; in addition dealers of the petitioner have also been instructed not to make payments to the petitioner through other bank accounts. Learned counsel for the petitioner has referred to Circular dated 22.08.2015 of the Central Board of Excise and Customs, Department of Revenue, Ministry of Finance, Govt. Learned counsel for the petitioner has referred to Circular dated 22.08.2015 of the Central Board of Excise and Customs, Department of Revenue, Ministry of Finance, Govt. of India to contend that even after garnishee notices are issued recovery of arrears may be permitted in installments. Petitioner has been paying the tax dues in substantial amount; it had paid about 19,00,000.00 in December, 2018 and in January, 2019 it had paid Rs. 5,00,000.00 etc. Mr. Sarma learned counsel representing respondent No. 2 may obtain instruction regarding the prayer of the petitioner to allow payment of service tax dues in installments. In the meanwhile, no further coercive measures may be taken against the petitioner. List on 27.02.2019." The said interim order is holding the field. Even if recovery notices were issued by Assistant Commissioner of Goods and Service Tax prior to passing of the interim order, as the same is holding the field, no further steps shall be taken on the basis of the said notices and such notices issued under Section 87(b) of the Finance Act, 1994 read with Section 174(2)(e) of the Central Goods and Service Tax Act, 2017 would not be acted upon until further orders. However, these notices shall be subject to outcome of the writ petition. IA is disposed of." 12. Basic contention of learned counsel for the petitioner is that having regard to Section 73 of the Finance Act, 1994, in a case where service tax is not levied or paid or short levied or short paid or erroneously refunded, the competent Central Excise Officer (now, GST Officer) shall issue show cause notice to the assessee within 30 months as to why the amount specified in the notice should not be paid. This period of 30 months is extendable upto 5 years in a case of fraud, collusion, willful misstatement etc. No such notice was issued to the petitioner within 30 months. Without issuing such show-cause notice under Section 73, impugned garnishee notices could not have been issued under Section 87 (b) of the Finance Act, 1994. Referring to Section 75 of the Finance Act, 1994, learned counsel submits in case of failure to pay tax or any part thereof within the period prescribed, simple interest @ not below 10% and not exceeding 36% per annum may be levied. Referring to Section 75 of the Finance Act, 1994, learned counsel submits in case of failure to pay tax or any part thereof within the period prescribed, simple interest @ not below 10% and not exceeding 36% per annum may be levied. Therefore, though levy of interest in a case covered under Section 73 may be automatic, there is a wide range regarding payment of interest, i.e., between 10% to 36%. Application of mind and adjudication would be required for a particular rate of interest that may be imposed on a defaulting dealer. 12.1. In the instant case, respondent No. 2 had automatically imposed interest at the highest rate which is not justified. Learned counsel for the petitioner has placed reliance on a decision of the Single Bench of the Karnataka High Court in Prasanthi Vs. Union of India; WP(C) No. 14054/2015, decided on 29.04.2015 and contends that garnishee notices, not to speak of imposition of interest, can only be issued post adjudication. Without adjudication of liability and interest, no garnishee notice can be issued. 12.2. Though learned counsel for the petitioner had made other submissions regarding Section 174 of the Central Goods and Service Tax Act, 2017, more particularly, relating to omission of Finance Act, 1994, considering the nature of dispute and the order which the Court proposes to pass, it may not be necessary to refer to such submissions made and thereafter to make deliberations thereon. 13. Mr. B Sarma, learned Standing Counsel, Central Excise Department for respondent No. 2, has referred to the averments made in the counter affidavit and submits that petitioner is a defaulter of service tax liability amounting to Rs. 6,05,07,272.00 which has accumulated since the year 2013. The service tax amount has already been collected from the customers during the period from April, 2013 to September, 2016, but not paid to the Government exchequer despite several communications and reminders. Ultimately, the Department had to issue notice to the banker of the petitioner under Section 87 (b)(i) of the Finance Act, 1994. On such notice, State Bank of India had remitted an amount of Rs. 8,10,000.00. Petitioner itself came forward and assured the Commissioner to pay the entire outstanding dues in eight equated quarterly installments. However, not a single installment has been paid. Because of such assurance, the Department did not take any further action till January, 2019. On such notice, State Bank of India had remitted an amount of Rs. 8,10,000.00. Petitioner itself came forward and assured the Commissioner to pay the entire outstanding dues in eight equated quarterly installments. However, not a single installment has been paid. Because of such assurance, the Department did not take any further action till January, 2019. Though substantial amounts were deposited in the bank account of the petitioner in the State Bank of India, Commercial Branch, these amounts were debited by the petitioner instead of being credited into the Central Government exchequer. Regarding payment of installments, he submits that as per circular dated 28.02.2015, Commissioner may permit payment of arrears in installments upto a maximum of 24 monthly installments and the Chief Commissioner may permit upto maximum of 36 monthly installments. However, permission to pay dues in installments is subject to the condition that the authority must be satisfied that the assessee is not a frequent defaulter and that the financial condition of the defaulter is under temporary distress. In so far petitioner is concerned, balance sheets for the years 2013-2014 to 2017-2018 do not indicate any financial distress of the petitioner. Therefore, the facility of payment of arrear dues in installments may not be extended to the petitioner. He, therefore, submits that the writ petition is devoid of merit and is liable to be dismissed. 14. In her reply submissions, Ms Hawelia, learned counsel for the petitioner submits that petitioner is at present paying GST at the rate of Rs. 22 to 25 lacs per month and, therefore, if the entire amount of service tax dues is required to be paid at one go, petitioner may not be able to pay the same. On a query by the Court learned counsel for the petitioner submits that petitioner is in a position to pay installment of Rs. 6 lacs per month till the arrear service tax dues are cleared. Regarding the interest portion, she submits that the rate of interest has to be adjudicated upon before the same is imposed on the assessee. Therefore, the interest part be remanded back to respondent No. 2. 15. Submissions made by learned counsel for the parties have been considered. Also perused the materials on record. 16. Regarding the interest portion, she submits that the rate of interest has to be adjudicated upon before the same is imposed on the assessee. Therefore, the interest part be remanded back to respondent No. 2. 15. Submissions made by learned counsel for the parties have been considered. Also perused the materials on record. 16. Since learned counsel for the petitioner has placed reliance on the decision of the Karnataka High Court in Prashanthi (supra), the same may be adverted to at the outset. In Prashanthi (supra), the issue was issuance of recovery notices under Section 87 of the Finance Act, 1994 without there being any adjudication under Section 73 of the said Act. In fact, the question formulated by the Karnataka High Court for its consideration was whether respondents could have initiated recovery proceedings under Section 87 of the Finance Act, 1994, when there was no adjudication or quantification of the amount due and payable by the registered service tax provider. Karnataka High Court considered the provisions of Sections 73 and 87 of the Finance Act, 1994 along with other provisions of the said Act as well as Rule 6 A of the Service Tax Rules, 1994 and came to the conclusion that power vested under Section 87 (b)(i) and (ii) of the Finance Act, 1994 can be exercised only after adjudication of the show cause notice is concluded. Since there was no adjudication prior to issuance of the garnishee notices, Karnataka High Court quashed the recovery notices. 17. Having noticed the above, Section 73 of the Finance Act, 1994 may be adverted too. Section 73 is extracted hereunder:- Section 73. Since there was no adjudication prior to issuance of the garnishee notices, Karnataka High Court quashed the recovery notices. 17. Having noticed the above, Section 73 of the Finance Act, 1994 may be adverted too. Section 73 is extracted hereunder:- Section 73. Recovery of service tax not levied or paid or short-levied or short-paid or erroneously refunded.- (1) Where any service tax has not been levied or paid or has been short-levied or short paid or erroneously refunded, Central Excise Officer may, within thirty months from the relevant date, serve notice on the person chargeable with the service tax which has not been levied or paid or which has been short-levied or short-paid or the person to whom such tax refund has erroneously been made, requiring him to show cause why he should not pay the amount specified in the notice: Provided that where any service tax has not been levied or paid or has been short-levied or short-paid or erroneously refunded by reason of- (a) fraud; or (b) collusion; or (c) wilful mis-statement; or (d) suppression of facts; or (e) contravention of any of the provisions of this Chapter or of the rules made thereunder with intent to evade payment of service tax, by the person chargeable with the service tax or his agent, the provisions of this sub-section shall have effect, as if, for the words ''thirty months", the words "five years" had been substituted. Explanation.-Where the service of the notice is stayed by an order of a court, the period of such stay shall be excluded in computing the aforesaid period of eighteen months or five years, as the case may be. Explanation.-Where the service of the notice is stayed by an order of a court, the period of such stay shall be excluded in computing the aforesaid period of eighteen months or five years, as the case may be. (1A) Where any service tax has not been levied or paid or has been short-levied or short paid or erroneously refunded, by reason of fraud, collusion or any willful misstatement or suppression of facts, or contravention of any of the provisions of this Chapter or the rules made thereunder, with intent to evade payment of service tax, by such person or his agent, to whom a notice is served under the proviso to Sub-Section (1) by the Central Excise Officer, such person or gent may pay service tax in full or in part as may be accepted by him, and the interest payable thereon under Section 75 and penalty equal to twenty-five per cent of the service tax specified in the notice or the service tax so accepted by such person within 30 days of the receipt of the notice. (2) The Central Excise Officer shall, after considering the representation, if any, made by the person on whom notice is served under sub-section (1), determine the amount of service tax due from, or erroneously refunded to, such person (not being in excess of the amount specified in the notice) and thereupon such person shall pay the amount so determined. Provided that where such person has paid the service tax in full together with interest and penalty under Sub-Section (1A), the proceedings in respect of such person and other persons to whom notices are served under Sub-Section (1) shall be deemed to be concluded. Provided further that where such person has paid service tax in part along with interest and penalty under Sub-Section (1A), the Central Excise Officer shall determine the amount of service tax or interest not being in excess of the amount partly due from such person. Provided further that where such person has paid service tax in part along with interest and penalty under Sub-Section (1A), the Central Excise Officer shall determine the amount of service tax or interest not being in excess of the amount partly due from such person. (3) Where any service tax has not been levied or paid or has been short-levied or short-paid or erroneously refunded, the person chargeable with the service tax, or the person to whom such tax refund has erroneously been made, may pay the amount of such service tax, chargeable or erroneously refunded, on the basis of his own ascertainment thereof, or on the basis of tax ascertained by a Central Excise Officer before service of notice on him under sub-section (1) in respect of such service tax, and inform the [Central Excise Officer] of such payment in writing, who, on receipt of such information shall not serve any notice under sub-section (1) in respect of the amount so paid: Provided that the Central Excise Officer may determine the amount of short-payment of service tax or erroneously refunded service tax, if any, which in his opinion has not been 18 paid by such person and, then, the Central Excise Officer shall proceed to recover such amount in the manner specified in this section, and the period of "thirty months" referred to in sub-section (1) shall be counted from the date of receipt of such information of payment Explanation- For the removal of doubts, it is hereby declared that the interest under section 75 shall be payable on the amount paid by the person under this sub-section and also on the amount of short payment of service tax or erroneously refunded service tax, if any, as may be determined by the [Central Excise Officer], but for this sub-section. (4) Nothing contained in sub-section (3) shall apply to a case where any service tax has not been levied or paid or has been short-levied or short-paid or erroneously refunded by reason of- (a) fraud; or (b) collusion; or (c) willful mis-statement; or (d) suppression of facts; or (e) contravention of any of the provisions of this Chapter or of the rules made thereunder with intent to evade payment of service tax. (5) The provisions of sub-section (3) shall not apply to any case where the service tax had become payable or ought to have been paid before the 14th day of May, 2003. (6) For the purposes of this section, "relevant date" means,- (i) in the case of taxable service in respect of which service tax has not been levied or paid or has been short-levied or short-paid- (a) where under the rules made under this Chapter, a periodical return, showing particulars of service tax paid during the period to which the said return relates, is to be filed by an assessee, the date on which such return is so filed; (b) where no periodical return as aforesaid is filed, the last date on which such return is to be filed under the said rules; (c) in any other case, the date on which the service tax is to be paid under this Chapter or the rules made thereunder; (ii) in a case where the service tax is provisionally assessed under this Chapter or the rules made there under, the date of adjustment of the service tax after the final assessment thereof; (iii) in a case where any sum, relating to service tax, has erroneously been refunded, the date of such refund. 18. A reading of Section 73 as extracted above would go to show that in the circumstances enumerated in Sub-Section (1) thereof the competent authority may within 18 months (and since 01.04.2017, 30 months), serve a show cause notice upon the assessee as to why he should not pay the amount specified in the notice. However, in a case of fraud the period for issuance of such notice would stand extended to 5 years. After service of show cause notice, if any representation is made by the assessee the same shall be considered and thereafter, the service tax dues may be determined. Further, in a case of self-assessment, the quantum of service tax dues along with interest shall be recovered under Section 87. 19. Section 75 deals with interest on delayed payment of service tax. As per this Section, in case of delay in payment of service tax the defaulter shall pay simple interest at such rate not below 10% and not exceeding 36% per annum for the period of default. 20. This brings us to Section 87 of the Finance Act, 1994. 19. Section 75 deals with interest on delayed payment of service tax. As per this Section, in case of delay in payment of service tax the defaulter shall pay simple interest at such rate not below 10% and not exceeding 36% per annum for the period of default. 20. This brings us to Section 87 of the Finance Act, 1994. Section 87 is extracted hereunder:- Section 87. As per this Section, in case of delay in payment of service tax the defaulter shall pay simple interest at such rate not below 10% and not exceeding 36% per annum for the period of default. 20. This brings us to Section 87 of the Finance Act, 1994. Section 87 is extracted hereunder:- Section 87. Recovery of any amount due to Central Government- Where any amount payable by a person to the credit of the Central Government under any of the provisions of this Chapter or of the rules made there under is not paid, the Central Excise Officer shall proceed to recover the amount by one or more of the modes mentioned below:- (a) the Central Excise Officer may deduct or may require any other Central Excise Officer or any officer of customs to deduct the amount so payable from any money owing to such person which may be under the control of the said Central Excise Officer or any officer of customs; (b) (i) the Central Excise Officer may, by notice in writing, require any other person from whom money is due or may become due to such person, or who holds or may subsequently hold money for or on account of such person, to pay to the credit of the Central Government either forthwith upon the money becoming due or being held or at or within the time specified in the notice, not being before the money becomes due or is held, so much of the 31 money as is sufficient to pay the amount due from such person or the whole of the money when it is equal to or less than that amount; (ii) every person to whom a notice is issued under this section shall be bound to comply with such notice, and in particular, where any such notice is issued to a post office, banking company or an insurer, it shall not be necessary to produce any pass book, deposit receipt, policy or any other document for the purpose of any entry, endorsement or the like being made before payment is made, notwithstanding any rule, practice or requirement to the contrary; (iii) in a case where the person to whom a notice under this section is sent, fails to make the payment in pursuance thereof to the Central Government, he shall be deemed to be an assessee in default in respect of the amount specified in the notice and all the consequences of this Chapter shall follow, (c) the Central Excise Officer may, on an authorisation by the Principal Commissioner of Central Excise or Commissioner of Central Excise, in accordance with the rules made in this behalf, distrain any movable or immovable property belonging to or under the control of such person, and detain the same until the amount payable is paid; and in case, any part of the said amount payable or of the cost of the distress or keeping of the property, remains unpaid for a period of thirty days next after any such distress, may cause the said property to be sold and with the proceeds of such sale, may satisfy the amount payable and the costs including cost of sale remaining unpaid and shall render the surplus amount, if any, to such person; (d) the Central Excise Officer may prepare a certificate signed by him specifying the amount due from such person and send it to the Collector of the district in which such person owns any property or resides or carries on his business and the said Collector, on receipt of such certificate, shall proceed to recover from such person the amount specified there under as if it were an arrear of land revenue. 21. A conjoint reading of Sections 73 and 87 of the Finance Act, 1994 would go to show that in case of non-payment of service tax dues covered by the situations enumerated, the competent authority is empowered to issue show cause notice within the time frame provided for payment of service tax dues specified in the notice, the period of notice would stand extended in a case of fraud. If the assessee submits a representation regarding the show cause notice, the same has to be considered before quantifying the service tax dues. Therefore, an element of adjudication is inbuilt in Section 73. However, there is an exception in a case of self assessment in which case the defaulted amount shall be recovered under Section 87, meaning thereby that in a case of self-assessment, no adjudication may be necessary. 22. Keeping the above in mind, a consideration of the case projected by the petitioner would indicate that petitioner has not disputed the quantum of service tax dues quantified in the garnishee notices. Petitioner has only highlighted the need and necessity to allow it to pay the dues in installments. Therefore, in a case where the assessee admits to the service tax dues as specified in the show cause notice or in the garnishee notice, no adjudication would be necessary. To that extent, decision of the Karnataka High Court in Prashanthi (supra), is distinguishable on facts. 23. Before dealing with the prayer of the petitioner for payment of service tax dues in installments, it would be apposite to first deal with the question of interest. As already noticed above, Section 75 of the Finance Act, 1994, deals with levy of interest on delayed payment of service tax. It provides for payment of simple interest at such rate not below 10% and not exceeding 36% per annum for the period of delay. It is thus clear that the interest that may be imposed in case of delayed payment of service tax is not a fixed percentage but ranges between 10% to 36% indicating an element of flexibility. What would be the interest in a particular case would depend upon the facts and circumstances of that case for which discretion is vested on the competent officer. Such discretion perforce has to be exercised in a fair and judicious manner and cannot be exercised mechanically to levy the maximum rate of interest. What would be the interest in a particular case would depend upon the facts and circumstances of that case for which discretion is vested on the competent officer. Such discretion perforce has to be exercised in a fair and judicious manner and cannot be exercised mechanically to levy the maximum rate of interest. In the instant case, what is seen is that respondent No. 2 has imposed the maximum percentage of interest i.e., 36% without any exercise of discretion which indicates non-application of mind. Thus, the exercise is arbitrary. 24. That brings us to the last issue that is payment of service tax dues in installments. In this connection, reference may be made to circular dated 28.02.2015, issued by the Government of India, Ministry of Finance, Department of Revenue, Central Board of Excise and Customs, which deals with recovery of arrears in installments and amendment of garnishee notice. It has been clarified that the recovery officer has the power to add, amend, vary or rescind any garnishee notice issued, however, safeguarding the interest of the revenue. Regarding payment of arrears in installments, it has also been clarified that the Central Board of Excise and Customs has allowed recovery of arrears of taxes, interest and penalty in installments. As per the said circular, Commissioners have been given the discretion for granting sanction to pay arrears in installments upto a maximum of 24 monthly installments and Chief Commissioners more than 24 and upto a maximum of 36 monthly installments. It has been emphasized that approval to pay in installments and the number of installments should be fixed in such a way so that an appropriate balance is maintained between recovery of arrears and survival of business. 25. After thorough consideration of the entire matter and taking an overall view, the following orders/directions are issued:- (1) The interest portion covered by the garnishee notices is set aside. (2) In so far payment of interest is concerned, matter is remanded to respondent No. 2 who shall take an appropriate decision regarding the percentage of interest that may be levied after giving an opportunity of hearing to the petitioner. (3) Regarding the arrear service tax dues dehors the interest amount, the same shall be paid by the petitioner in 48 equated monthly installments, commencing from 15.09.2019. 26. With the above order and directions, writ petition is disposed of. No costs.