JUDGMENT : (Hon’ble Shekhar B. Saraf, J.) : 1. The instant writ petition under Article 226 of the Constitution of India has been filed by Vinod Kumar Jain (hereinafter referred to as the ‘Petitioner’) assailing the order dated December 7, 2006 passed by the District Magistrate/Collector, Jhansi (hereinafter referred to as the ‘Respondent No. 2’). FACTS 2. The facts giving rise to the instant writ petition are delineated below: a. The Petitioner purchased certain plots of land vide a registered sale deed dated July 17, 2002 and the paid stamp duty on the same. b. The name of the Petitioner was recorded in revenue records as bhumidhar with transferable rights. c. After a period of three years from the date of execution of the sale deed, the Petitioner was served with a show cause notice dated January 7, 2005 which was based on an alleged inspection report dated December 4, 2004. d. On the date fixed, that is on June 26, 2006, the authority concerned proceeded with the matter ex parte and passed an order on the same day imposing deficiency of stamp, penalty along with interest on the Petitioner. The Petitioner submitted an application on the same day before the authority concerned in order for his reply to be taken on record. However, the authority concerned rejected the said application saying that since the order has been passed, the reply will not be considered. e. Aggrieved with the aforesaid order dated June 26, 2006 the Petitioner approached this Court by way of a writ petition which was dismissed by this Court on the ground that the Petitioner had an alternative efficacious remedy available. f. Thereafter, the Petitioner preferred a revision application before the Respondent No.2 and deposited 1/3rd of the deficit amount as alleged by the Department. The said revision application was dismissed vide order dated December 7, 2006. g. Aggrieved by the order dated December 7, 2006, the Petitioner has preferred the instant writ petition before this Court. CONTENTIONS OF THE PETITIONER 3. Learned counsel appearing on behalf of the Petitioner has made the following submissions: a. The nature of the land at the time of execution of the sale deed dated July 17, 2002 was agricultural and the same has been admitted by the Respondent No.2 in his order dated June 26, 2006. CONTENTIONS OF THE PETITIONER 3. Learned counsel appearing on behalf of the Petitioner has made the following submissions: a. The nature of the land at the time of execution of the sale deed dated July 17, 2002 was agricultural and the same has been admitted by the Respondent No.2 in his order dated June 26, 2006. b. The authorities concerned have treated the land as non-agricultural for the purposes of levying additional stamp duty. This too has been done after three years of the execution of the registered instrument without there being any material basis to do so or any exemplar to compare. c. No notice was give to the Petitioner regarding the alleged spot verification. The same has also not been denied by the Respondents. The spot verification was not carried out as per Rule 7(3)(c) of the Uttar Pradesh Stamp (Valuation of Property) Rules, 1997 (hereinafter referred to as "the Rules"), which is mandatory. d. As per Rule 7(3)(c) of the Rules, spot inspection has to be conducted after giving due notice to the parties to the instrument. While a spot inspection was conducted on January 4, 2004, no notice of the same was ever given to the Petitioner. After the said spot inspection, a show cause notice dated January 7, 2005 was issued to the Petitioner. e. At the relevant point of time, the land in question was agricultural in nature and there were no structures or any activity apart from agriculture being carried out on the said land. f. The Collector must have material on record to come to a finding as to the potential use of the land and only thereafter, assess the same on the basis of such potential use. g. Spot inspection report does not disclose any material relied upon to come to the conclusion that the Petitioner's land is non-agricultural in nature. h. Respondents do not dispute the fact that the Petitioner's land was being used only for agricultural purposes at the time of execution of the sale deed and also at the time of the alleged spot inspection. CONTENTIONS OF THE RESPONDENTS 4. h. Respondents do not dispute the fact that the Petitioner's land was being used only for agricultural purposes at the time of execution of the sale deed and also at the time of the alleged spot inspection. CONTENTIONS OF THE RESPONDENTS 4. Learned Additional Chief Standing Counsel appearing on behalf of the State Respondents has made the following submissions: a. A proceeding under Section 47-A of the Act was initiated on the basis of the report of the Tehsildar which indicated that true facts were not stated in the sale deed as provided under Section 27 of the Act. As per relevant provisions of the Rules, the Petitioner has not paid stamp duty correctly. b. The Petitioner did not file any reply to the show cause notice issued against him even after several opportunities were provided for the same. c. The Collector, Jhansi, after considering the report of the Tehsildar and the Committee and the relevant provisions has determined the deficiency along with penalty. d. The Collector placed reliance on the spot inspection report of the revenue authority, which was based on the prevailing market value at the time of registration of the sale deed. The order of the Collector, Jhansi determining the deficiency was in accordance with the relevant provisions. e. The Petitioner despite the opportunity being given could not produce any reliable evidence in support of his case and as such the Respondent No.2 has rightly dismissed the revision application filed by the Petitioner as the Respondent No.2 did not find any grounds to interfere with the earlier order passed by Collector. f. The order impugned in the instant writ petition was passed after affording full opportunity of hearing as per the relevant provisions and applicable rates prevailing in the market. g. The reports submitted by Tehsildar, Asst. Commissioner Stamp and the Additional Collector (F&R) were on record and the contention of the Petitioner in this regard is misconceived. ANALYSIS AND CONCLUSION 5. I have heard the learned counsel appearing for the parties and perused the materials on record. 6. On the power of the Collector under Section 47-A of the Act, reference can be made to the judgment of the Full Bench of this Court in Smt. Pushpa Sareen v. State of Uttar Pradesh reported in (2015) 0 Supreme (All) 132 penned by the Hon’ble Dr. D.Y. Chandrachud, C.J. (as his Lordship then was). 6. On the power of the Collector under Section 47-A of the Act, reference can be made to the judgment of the Full Bench of this Court in Smt. Pushpa Sareen v. State of Uttar Pradesh reported in (2015) 0 Supreme (All) 132 penned by the Hon’ble Dr. D.Y. Chandrachud, C.J. (as his Lordship then was). The relevant paragraphs are extracted herein: “26. The true test for determination by the Collector is the market value of the property on the date of the instrument because, under the provisions of the Act, every instrument is required to be stamped before or at the time of execution. In making that determination, the Collector has to be mindful of the fact that the market value of the property may vary from location to location and is dependent upon a large number of circumstances having a bearing on the comparative advantages or disadvantages of the land as well as the use to which the land can be put on the date of the execution of the instrument. 27. Undoubtedly, the Collector is not permitted to launch upon a speculative inquiry about the prospective use to which a land may be put to use at an uncertain future date. The market value of the property has to be determined with reference to the use to which the land is capable reasonably of being put to immediately or in the proximate future. The possibility of the land becoming available in the immediate or near future for better use and enjoyment reflects upon the potentiality of the land. This potential has to be assessed with reference to the date of the execution of the instrument. In other words, the power of the Collector cannot be unduly circumscribed by ruling out the potential to which the land can be advantageously deployed at the time of the execution of the instrument or a period reasonably proximate thereto. Again the use to which land in the area had been put is a material consideration. If the land surrounding the property in question has been put to commercial use, it would be improper to hold that this is a circumstance which should not weigh with the Collector as a factor which influences the market value of the land. 28. Again the use to which land in the area had been put is a material consideration. If the land surrounding the property in question has been put to commercial use, it would be improper to hold that this is a circumstance which should not weigh with the Collector as a factor which influences the market value of the land. 28. The fact that the land was put to a particular use, say for instance a commercial purpose at a later point in time, may not be a relevant criterion for deciding the value for the purpose of stamp duty, as held by the Supreme Court in State of Uttar Pradesh and others vs. Ambrish Tandon and another11. This is because the nature of the user is relateable to the date of purchase which is relevant for the purpose of computing the stamp duty. Where, however, the potential of the land can be assessed on the date of the execution of the instrument itself, that is clearly a circumstance which is relevant and germane to the determination of the true market value. At the same time, the exercise before the Collector has to be based on adequate material and cannot be a matter of hypothesis or surmise. The Collector must have material on the record to the effect that there has been a change of use or other contemporaneous sale deeds in respect of the adjacent areas that would have a bearing on the market value of the property which is under consideration. The Collector, therefore, would be within jurisdiction in referring to exemplars or comparable sale instances which have a bearing on the true market value of the property which is required to be assessed. If the sale instances are comparable, they would also reflect the potentiality of the land which would be taken into consideration in a price agreed upon between a vendor and a purchaser.” 7. Upon a perusal of the judgment in Smt. Pushpa Sareen’s case (supra), what emerges is that the Collector can assess the potential use of the land on the date of execution of the instrument for determination of true market value. However, this exercise by the Collector has to be based on adequate materials and cannot be a matter of hypothesis or surmise. The Collector’s finding as to the potential use of the land must be backed by sufficient evidence. However, this exercise by the Collector has to be based on adequate materials and cannot be a matter of hypothesis or surmise. The Collector’s finding as to the potential use of the land must be backed by sufficient evidence. In the absence of any materials or sufficient evidence to support its findings, the Collector cannot base his valuation on conjectures and surmises. 8. Further reliance can be placed on the judgment of a Coordinate Bench of this Court in Raj Kumar v. State of Uttar Pradesh and others (Writ-C No.19644 of 2016 decided on April 13, 2023) wherein it was held that spot inspection has to be carried out in terms of Rule 7(3)(c) of the Rules. Furthermore, the Court held that burden of proof is on the State to establish the payment of deficient stamp duty. It was further held that the valuation of the land in question has to be made on concrete grounds. The relevant paragraphs of Raj Kumar’s case (supra) are delineated below: 17. Moreover, had the allegation of the State been to the effect that though the land was purchased for agricultural purposes, but its user was immediately changed and on the date of sale deed, it was being used for any other purpose like, industrial, commercial or even residential, the situation would have been different. Even in those situations, spot inspection at the relevant point of time was a necessity, but, admittedly, in the present case, no spot inspection has been carried out. Necessity of spot inspection and its mandatory nature, with reference to Rule 7 (3) (c) of the aforesaid Rules of 1997, has been reiterated, time and again by this Court in various authorities including Ajay Agarwal and others vs Commissioner Lucknow and others, reported in 2023 (2) ADJ 561 (LB), and Ram Khelawan alias Bachcha vs State of Uttar Pradesh and another, reported in 2005 (2) AWC 1087 . ***** 19. The observations/findings recorded in the orders impugned are also contrary to principles of burden of proof particularly, in a case where proceedings arise out of a fiscal statute. ***** 19. The observations/findings recorded in the orders impugned are also contrary to principles of burden of proof particularly, in a case where proceedings arise out of a fiscal statute. Once the State was proceeding to impose deficient stamp duty upon the petitioner, the entire burden lay upon the State to establish beyond reasonable doubt that the petitioner made some concealment at the time of getting the sale deed executed in his favour or that within a close proximity of dates, the user of the land in dispute was changed so as to levy additional stamp duty. Nothing to this effect has been brought on record, rather, not only the findings recorded in the orders impugned are contrary to the provisions of the Indian Stamp Act, 1899, as applicable in the State of Uttar Pradesh as well as Uttar Pradesh Stamp (Valuation of Property) Rules, 1997, but certainly contrary to the law consistently laid down by this Court. 9. When the State seeks to impose additional financial liabilities, such as higher stamp duty, it must provide clear and compelling evidence to justify its claims. This principle ensures that property owners are not subjected to arbitrary or unjustified financial burdens. It serves as a cornerstone of fairness and accountability in the legal process, protecting individuals and entities from potential misuse of governmental power. In the context of stamp duty, the burden of proof involves demonstrating that the assessed value of the property, and thus the calculated duty, is accurate and based on tangible, verifiable data. This requirement is essential to prevent arbitrary valuations that could result from assumptions or inadequate investigations. By ensuring that the State must justify its claims with clear evidence, the principle safeguards property owners from potential overreach and ensures that any additional financial burdens are warranted and fair. Courts have constantly underscored that when the State seeks to levy additional taxes or duties, it must do so based on robust and substantiated evidence. For instance, in the case of Raj Kumar v. State of U.P (supra), this Court highlighted that the entire burden of establishing the necessity for additional stamp duty lies with the State. This Court emphasized that without concrete evidence demonstrating a change in the land's use or value, the imposition of additional duty would be unfounded and unjust. For instance, in the case of Raj Kumar v. State of U.P (supra), this Court highlighted that the entire burden of establishing the necessity for additional stamp duty lies with the State. This Court emphasized that without concrete evidence demonstrating a change in the land's use or value, the imposition of additional duty would be unfounded and unjust. Similarly, in the landmark case of Smt. Pushpa Sareen v. State of Uttar Pradesh (supra), the Full Bench of this Court elaborated on the nature and extent of evidence required from the State. The judgment in Pushpa Sareen (supra) underscored that the State must provide detailed and specific evidence about the land’s current use, potential use, and market value. General assumptions or indirect evidence are insufficient to meet this burden. The court's insistence on a high standard of proof reflects the principle's role in ensuring fairness and protecting property owners' rights. 10. In the present case, indubitably the spot verification was not carried out as per the Rules. Such being the case, the burden of proof that rested solely on the Revenue to indicate the nature of the land and the potential use of the land was not discharged properly. The spot verification was conducted without affording an opportunity to the Petitioners, and the same cannot be sustained. 11. It is trite law that principles of audi alteram partem are required to be followed by the authority and giving a go by to the same results in violation of the principles of natural justice. One may examine the development of the law in relation to natural justice. The Division Bench of this Court in S.R. Cold Storage v. Union of India and Others reported in 2022 SCC online (All) 550; {[2022] 448 ITR 37 (All)} held as follows: “25. The first and foremost principle of natural justice is commonly known as audi alteram partem rule. It says that no one should be condemned unheard. Notice is the first limb of this principle. It must be precise and unambiguous. It should appraise the party determinatively the case he has to meet. Time given for the purpose should be adequate so as to enable him to make his representation. In the absence of a notice of the kind and reasonable opportunity, the order passed becomes wholly vitiated. It must be precise and unambiguous. It should appraise the party determinatively the case he has to meet. Time given for the purpose should be adequate so as to enable him to make his representation. In the absence of a notice of the kind and reasonable opportunity, the order passed becomes wholly vitiated. Thus, it is but essential that a party should be put on notice of the case before any adverse order is passed against him. It is an approved rule of fair play. 26. The principles of natural justice are those rules which have been laid down by the courts as being the minimum protection of the rights of the individual against the arbitrary procedure that may be adopted by a judicial, quasi-judicial and administrative authority while making an order affecting those rights. These rules are intended to prevent such authority from doing injustice. Even an administrative order which involves civil consequences must be consistent with the rules of natural justice. 27. The expression "civil consequences" encompasses infraction of not merely property or personal rights but of civil liberties, material deprivations, and non-pecuniary damages. In its wide umbrella comes everything that affects a citizen in his civil life. 28. Natural justice has been variously defined by different judges, for instance a duty to act fairly, the substantial requirements of justice, the natural sense of what is right and wrong, fundamental justice and fair-play in action. Over the years by a process of judicial interpretation two rules have been evolved as representing the principles of natural justice in judicial process, including therein quasi-judicial and administrative process. They constitute the basic elements of a fair hearing, having their roots in the innate sense of man for fair-play and justice which is not the preserve of any particular race or country but is shared in common by all men. The first rule is "nemo judex in causa sua" or "nemo debet esse judex in propria causa sua" that is no man shall be a judge in his own cause. The second rule is "audi alteram partem", that is, "hear the other side". The first rule is "nemo judex in causa sua" or "nemo debet esse judex in propria causa sua" that is no man shall be a judge in his own cause. The second rule is "audi alteram partem", that is, "hear the other side". A corollary has been deduced from the above two rules and particularly the audi alteram partem rule, i. e., "he who shall decide anything without the other side having been heard, although he may have said what is right, will not have been what is right" or in other words, as it is now expressed, "justice should not only be done but should manifestly be seen to be done". Natural justice is the essence of fair adjudication, deeply rooted in tradition and conscience, to be ranked as fundamental. The purpose of following the principles of natural justice is the prevention of miscarriage of justice.” 12. The Supreme Court, in the celebrated constitutional judgment in Mrs. Maneka Gandhi v. Union of India and another reported in (1978) 1 SCC 248 , while dealing with a challenge laid to an order by which a passport was impounded, expounded upon the significance of the principles of audi alteram partem to the doctrine of natural justice. Justice P.N. Bhagwati while authoring the judgment beautifully expounded the said principles as follows: “14. But at the same time it must be remembered that this is a rule of vital importance in the field of administrative law and it must not be jettisoned save in very exceptional circumstances where compulsive necessity so demands. It is a wholesome rule designed to secure the rule of law and the court should not be too ready to eschew it in its application to a given case. True it is that in questions of this kind a fanatical or doctrinaire approach should be avoided, but that does not mean that merely because the traditional methodology of a formalised hearing may have the effect of stultifying the exercise of the statutory power, the audi alteram partem should be wholly excluded. The court must make every effort to salvage this cardinal rule to the maximum extent permissible in a given case. It must not be forgotten that “natural justice is pragmatically flexible and is amenable to capsulation under the compulsive pressure of circumstances”. The court must make every effort to salvage this cardinal rule to the maximum extent permissible in a given case. It must not be forgotten that “natural justice is pragmatically flexible and is amenable to capsulation under the compulsive pressure of circumstances”. The audi alteram partem rule is not cast in a rigid mould and judicial decisions establish that it may suffer situational modifications. The core of it must, however, remain, namely, that the person affected must have a reasonable opportunity of being heard and the hearing must be a genuine hearing and not an empty public relations exercise. That is why Tucker, L.J., emphasised in Russel v. Duke of Norfolk [(1949) 1 All ER 109] that “whatever standard of natural justice is adopted, one essential is that the person concerned should have a reasonable opportunity of presenting his case”. What opportunity may be regarded as reasonable would necessarily depend on the practical necessities of the situation. It may be a sophisticated full-fledged hearing or it may be a hearing which is very brief and minimal : it may be a hearing prior to the decision or it may even be a post-decisional remedial hearing. The audi alteram partem rule is sufficiently flexible to permit modifications and variations to suit the exigencies of myriad kinds of situations which may arise.” 13. Subsequently, the Supreme Court, in State of Kerala v. K.T. Shaduli Grocery Dealer Etc. reported in (1977) 2 SCC 777 , examined the principle of natural justice as follows: “2. Now, the law is well settled that tax authorities entrusted with the power to make assessment of tax discharge quasi-judicial functions and they are bound to observe principles of natural justice in reaching their conclusions. It is true, as pointed out by this Court in Dhakeswari Cotton Mills Ltd. v. CIT [ AIR 1955 SC 154 : (1955) 1 SCR 941 : (1955) 27 ITR 126 ] that a taxing officer “is not fettered by technical rules of evidence and pleadings, and that he is entitled to act on material which may not be accepted as evidence in a court of law”, but that does not absolve him from the obligation to comply with the fundamental rules of justice which have come to be known in the jurisprudence of administrative law as principles of natural justice. It is, however, necessary to remember that the rules of natural justice are not a constant: they are not absolute and rigid rules having universal application. It was pointed out by this Court in Suresh Koshy George v. University of Kerala [ AIR 1969 SC 198 : (1969) 1 SCR 317 : (1969) 1 SCJ 543 ] that “the rules of natural justice are not embodied rules” and in the same case this Court approved the following observations from the judgment of Tucker, L.J. in Russel v. Duke of Norfolk [(1949) 1 All ER 109] : “There are, in my view, no words which are of universal application to every kind of inquiry and every kind of domestic tribunal. The requirements of natural justice must depend on the circumstances of the case, the nature of the inquiry, the rules under which the tribunal is acting, the subject-matter that is being dealt with, and so forth. Accordingly I do not derive much assistance from the definitions of natural justice which have been from time to time used, but, whatever standard is adopted, one essential is that the person concerned should have a reasonable opportunity of presenting his case.” 3. One of the rules which constitutes a part of the principles of natural justice is the rule of audi alteram partem which requires that no man should be condemned unheard. It is indeed a requirement of the duty to act fairly which lies on all quasi-judicial authorities and this duty has been extended also to the authorities holding administrative enquiries involving civil consequences or affecting rights of parties because as pointed out by this Court in A.K. Kraipak v. Union of India [ (1969) 2 SCC 262 : (1970) 1 SCR 457 ] “the aim of the rules of natural justice is to secure justice or to put it negatively, to prevent miscarriage of justice” and justice, in a society which has accepted socialism as its article of faith in the Constitution is dispensed not only by judicial or quasi-judicial authorities but also by authorities discharging administrative functions. This rule which requires an opportunity to be heard to be given to a person likely to be affected by a decision is also, like the genus of which it is a species, not an inflexible rule having a fixed connotation. This rule which requires an opportunity to be heard to be given to a person likely to be affected by a decision is also, like the genus of which it is a species, not an inflexible rule having a fixed connotation. It has a variable content depending on the nature of the inquiry, the framework of the law under which it is held, the constitution of the authority holding the inquiry, the nature and character of the rights affected and the consequences flowing from the decision. It is, therefore, not possible to say that in every case the rule of audi alteram partem requires that a particular specified procedure is to be followed. It may be that in a given case the rule of audi alteram partem may import a requirement that witnesses whose statements are sought to be relied upon by the authority holding the inquiry should be permitted to be cross-examined by the party affected while in some other case it may not. The procedure required to be adopted for giving an opportunity to a person to be heard must necessarily depend on facts and circumstances of each case.” 14. Justice P.N. Bhagwati further expounded on the necessity of disclosing to the assessee the information relied upon by the authorities. The relevant extract is provided below: “12. This Court further fully approved of the four propositions laid down by the Lahore High Court in Seth Gurmukh Singh v. Commissioner of Income Tax [ (1944) 12 ITR 393 (Lahore HC)]. This Court was of the opinion that the Taxing Authorities had violated certain fundamental rules of natural justice in that they did not disclose to the assessee the information supplied to it by the departmental representatives. This Court was of the opinion that the Taxing Authorities had violated certain fundamental rules of natural justice in that they did not disclose to the assessee the information supplied to it by the departmental representatives. This case was relied upon by this Court in a later decision in Raghubar Mandal Harihar Mandal's case (supra) where it reiterated the decision of this Court in Dhakeswari Cotton Mills Ltd.'s case (supra), and while further endorsing the decision of the Lahore High Court in Seth Gurmukh Singh's case pointed out the rules laid down by the Lahore High Court for proceeding under sub-section (3) of Section 23 of the Income-tax Act and observed as follows: “The rules laid down in that decision were these: (1) While proceeding under sub-section (3) of section 23 of the Income-tax Act, the Income-tax Officer is not bound to rely on such evidence produced by the assessee as he considers to be false; (2) if he proposes to make an estimate in disregard of the evidence, oral or documentary, led by the assessee, he should in fairness disclose to the assessee the material on which he is going to found that estimate; (3) he is not however debarred from relying on private sources of information, which sources he may not disclose to the assessee at all; and (4) in case he proposes to use against the assessee the result of any private inquiries made by him, he must communicate to the assessee the substance of the information so proposed to be utilised to such an extent as to put the assessee in possession of full particulars of the case he is expected to meet and should further give him ample opportunity to meet it, if possible.” It will thus be noticed that this Court clearly laid down that while the Income-tax Officer was not debarred from relying on any material against the assessee, justice and fair-play demanded that the sources of information relied upon by the Income-tax Officer must be disclosed to the assessee so that he is in a position to rebut the same and an opportunity should be given to the assessee to meet the effect the aforesaid information.” 15. Going forward, the Supreme Court in Dharampal Satyapal Limited v. Deputy Commissioner of Central Excise, Gauhati and others reported in (2015) 8 SCC 519 outlined the fundamental importance of providing an opportunity for hearing before making any decision, and characterized it as a basic requirement in any legal proceedings. The Supreme Court further propounded that compliance with principles of natural justice is an implied mandatory requirement, and non-observance of these principles can invalidate the exercise of power. Relevant paragraphs have been extracted below: 28. It is on the aforesaid jurisprudential premise that the fundamental principles of natural justice, including audi alteram partem, have developed. It is for this reason that the courts have consistently insisted that such procedural fairness has to be adhered to before a decision is made and infraction thereof has led to the quashing of decisions taken. In many statutes, provisions are made ensuring that a notice is given to a person against whom an order is likely to be passed before a decision is made, but there may be instances where though an authority is vested with the powers to pass such orders, which affect the liberty or property of an individual but the statute may not contain a provision for prior hearing. But what is important to be noted is that the applicability of principles of natural justice is not dependent upon any statutory provision. The principle has to be mandatorily applied irrespective of the fact as to whether there is any such statutory provision or not. *** 30. Wade [Administrative Law (1977) 395] also emphasises that principles of natural justice operate as implied mandatory requirements, non-observance of which invalidates the exercise of power. *** 35. From the aforesaid discussion, it becomes clear that the opportunity to provide hearing before making any decision was considered to be a basic requirement in the court proceeding. Later on, this principle was applied to other quasi-judicial authorities and other tribunals and ultimately it is now clearly laid down that even in the administrative actions, where the decision of the authority may result in civil consequences, a hearing before taking a decision is necessary. Later on, this principle was applied to other quasi-judicial authorities and other tribunals and ultimately it is now clearly laid down that even in the administrative actions, where the decision of the authority may result in civil consequences, a hearing before taking a decision is necessary. It was, thus, observed in A.K. Kraipak v. Union of India; [ (1969) 2 SCC 262 ] that if the purpose of rules of natural justice is to prevent miscarriage of justice, one fails to see how these rules should not be made available to administrative inquiries. In Maneka Gandhi v. Union of India; [ (1978) 1 SCC 248 ] also the application of principle of natural justice was extended to the administrative action of the State and its authorities. It is, thus, clear that before taking an action, service of notice and giving of hearing to the noticee is required. In Maharashtra State Financial Corporation v. Suvarna Board Mills; [ (1994) 5 SCC 566 ] , this aspect was explained in the following manner : “3. It has been contended before us by the learned counsel for the appellant that principles of natural justice were satisfied before taking action under Section 29, assuming that it was necessary to do so. Let it be seen whether it was so. It is well settled that natural justice cannot be placed in a straitjacket; its rules are not embodied and they do vary from case to case and from one fact-situation to another. All that has to be seen is that no adverse civil consequences are allowed to ensue before one is put on notice that the consequence would follow if he would not take care of the lapse, because of which the action as made known is contemplated. No particular form of notice is the demand of law. All will depend on facts and circumstances of the case.” 16. One may further refer to the recent judgment of the Supreme Court in Madhyamam Broadcasting Limited v. Union of India and others reported in ILR 2023 (2) Kerala 545; (2023 SCC OnLine 366) wherein the Hon’ble Supreme Court highlighted that the principles of natural justice of which audi alteram partem is a part, guarantee a reasonable procedure which is a requirement entrenched in Articles 14, 19 and 21 of the Constitution of India. Chief Justice Dr. Chief Justice Dr. D.Y. Chandrachud while authoring the judgment has succinctly examined the principles of natural justice and after examining the Supreme Court’s ratio in umpteen cases has penned the relevant paragraph which is extracted below: “47. The judgment of this Court in Maneka Gandhi (supra) spearheaded two doctrinal shifts on procedural fairness because of the constitutionalising of natural justice. Firstly, procedural fairness was no longer viewed merely as a means to secure a just outcome but a requirement that holds an inherent value in itself. In view of this shift, the Courts are now precluded from solely assessing procedural infringements based on whether the procedure would have prejudiced the outcome of the case [See S.L. Kapoor v. Jagmohan; (1980) 4 SCC 379 “The non-observance of natural justice is itself prejudice to any man and proof of prejudice independently of proof of denial of natural justice is unnecessary”; also see Swadeshi Cotton Mills v. Union of India; A.I.R. 1981 S.C. 818]. Instead, the courts would have to decide if the procedure that was followed infringed upon the right to a fair and reasonable procedure, independent of the outcome. In compliance with this line of thought, the courts have read the principles of natural justice into an enactment to save it from being declared unconstitutional on procedural grounds [See Olga Tellis v. Bombay Municipal Corporation: (1985) 3 SCC 545 ; C.B. Gautam v. Union of India: (1993) 1 SCC 78 ; Sahara India (Firm), Lucknow v. Commissioner of Income Tax, Central-I: (2008) 14 SCC 151 and Kesar Enterprises v. State of Uttar Pradesh: (2011) 13 SCC 733 ]. Secondly, natural justice principles breathe reasonableness into the procedure. Responding to the argument that the principles of natural justice are not static but are capable of being moulded to the circumstances, it was held that the core of natural justice guarantees a reasonable procedure which is a constitutional requirement entrenched in Articles 14, 19 and 21. The facet of audi alterum partem encompasses the components of notice, contents of the notice, reports of inquiry, and materials that are available for perusal. While situational modifications are permissible, the rules of natural justice cannot be modified to suit the needs of the situation to such an extent that the core of the principle is abrogated because it is the core that infuses procedural reasonableness. While situational modifications are permissible, the rules of natural justice cannot be modified to suit the needs of the situation to such an extent that the core of the principle is abrogated because it is the core that infuses procedural reasonableness. The burden is on the applicant to prove that the procedure that was followed (or not followed) by the adjudicating authority, in effect, infringes upon the core of the right to a fair and reasonable hearing.” 17. Chief Justice Dr. D.Y. Chandrachud has further elaborated on the principles of natural justice in State Bank of India and others v. Rajesh Agarwal and others reported in (2023) 6 SCC 1 . The relevant paragraph is delineated below: “36. We need to bear in mind that the principles of natural justice are not mere legal formalities. They constitute substantive obligations that need to be followed by decision-making and adjudicating authorities. The principles of natural justice act as a guarantee against arbitrary action, both in terms of procedure and substance, by judicial, quasi-judicial, and administrative authorities. Two fundamental principles of natural justice are entrenched in Indian jurisprudence: (i) nemo judex in causa sua, which means that no person should be a judge in their own cause; and (ii) audi alteram partem, which means that a person affected by administrative, judicial or quasi-judicial action must be heard before a decision is taken. The courts generally favor interpretation of a statutory provision consistent with the principles of natural justice because it is presumed that the statutory authorities do not intend to contravene fundamental rights. Application of the said principles depends on the facts and circumstances of the case, express language and basic scheme of the statute under which the administrative power is exercised, the nature and purpose for which the power is conferred, and the final effect of the exercise of that power.” 18. The common thread that runs across these judgments is that although the principle of audi alteram partem can evolve itself given the facts and circumstances of each case, its significance and applicability is universal. Audi alteram partem, which is a part of the doctrine of natural justice, finds its roots primarily in the constitutionally guaranteed ideal of equality. This principle ensures that no one is condemned, penalized, or deprived of their rights without a fair and reasonable opportunity of hearing. Audi alteram partem, which is a part of the doctrine of natural justice, finds its roots primarily in the constitutionally guaranteed ideal of equality. This principle ensures that no one is condemned, penalized, or deprived of their rights without a fair and reasonable opportunity of hearing. It acts as a safeguard against arbitrary decision-making, upholding the principle of due process while also providing a crucial foundation for just and equitable legal or administrative proceedings. 19. The principle of natural justice dictates that individuals affected by a decision must be given an opportunity to present their case and contest any adverse findings. This principle, often encapsulated in the Latin phrase "audi alteram partem" (hear the other side), is a fundamental aspect of fair legal procedures. When a spot inspection is conducted ex parte, it violates this principle by depriving the property owner of their right to be heard. 20. The importance of adhering to principles of natural justice in administrative actions has been repeatedly emphasized by the courts. In the case of Ridge v. Baldwin reported in [1964] AC 40 , the House of Lords held that failure to observe the principles of natural justice renders a decision void. Similarly, in Indian jurisprudence, the Supreme Court in Maneka Gandhi v. Union of India (supra) stressed the importance of the principles of natural justice. When the State conducts a spot inspection without involving the property owner, it undermines the credibility and fairness of the entire valuation process. The property owner is denied the chance to provide relevant information, challenge inaccurate observations, or present counter-evidence. This one-sided approach can lead to incorrect or biased assessments, resulting in unjust financial burdens on the property owner. 21. To rectify such procedural injustices, courts have the authority to set aside any actions or decisions made without adhering to the principles of natural justice. In the present case, since the spot inspection was carried out ex parte and without affording an opportunity to the Petitioner, the findings of that inspection cannot be sustained. 22. Accordingly, the impugned order dated December 7, 2006 is quashed and set aside. The amount, if any, deposited by the petitioner towards deficient stamp duty, should be returned to the petitioner along with interest @ 4 per cent within six weeks from date. Compliance in this regard must be filed by the Department after such payment is made. 23. 22. Accordingly, the impugned order dated December 7, 2006 is quashed and set aside. The amount, if any, deposited by the petitioner towards deficient stamp duty, should be returned to the petitioner along with interest @ 4 per cent within six weeks from date. Compliance in this regard must be filed by the Department after such payment is made. 23. With the above directions, this writ petition is allowed.