The Madras High Court has reaffirmed that public authorities cannot refuse to accept digitally submitted applications for essential permits, even in the absence of explicit statutory guidelines. This ruling ensures that administrative inaction does not undermine access to public services, particularly in the context of digital transformation.
Background & Facts
The Dispute
The petitioner, M. Ranjith Kumar, sought an auto rickshaw permit to operate within a 30-kilometer radius of Mettur Bus Stand in Salem District. He submitted his application on 03.12.2025 in Form CCPA, along with the prescribed fee, through the designated online portal. The Regional Transport Officer (RTO) refused to receive the application, citing alleged non-compliance with procedural norms, despite the absence of any statutory bar to online submissions.
Procedural History
The petitioner approached the High Court under Article 226 of the Constitution seeking a writ of mandamus. The matter was not litigated at any lower administrative forum, as the refusal was a direct, final denial of receipt, leaving no alternative remedy.
The Parties' Positions
- The petitioner relied on a prior judgment of the same court in A. Rajavel v. Regional Transport Officer, Salem East (W.P. No. 13551 of 2025), where the court had directed the RTO to accept online applications for similar permits.
- The petitioner also cited W.P. No. 17275 of 2025, where the same relief was granted under identical circumstances.
- The respondent, represented by the Additional Government Pleader, did not contest the legal principle but argued that the petitioner’s application was technically deficient.
Relief Sought
The petitioner sought a writ of mandamus compelling the RTO to receive his online application in Form CCPA and decide it on its merits within a stipulated timeframe.
The Legal Issue
The central question was whether an administrative authority may refuse to receive a digitally submitted permit application solely on the grounds of procedural unfamiliarity, when no statutory provision prohibits online submission and a binding precedent already mandates acceptance.
Arguments Presented
For the Petitioner
The petitioner’s counsel argued that the refusal to accept the application violated the principles of administrative fairness and non-arbitrariness under Article 14 of the Constitution. He relied on A. Rajavel v. RTO, Salem East and W.P. No. 17275 of 2025, both decided by the same bench, to establish that the court had already settled the issue. He emphasized that the state’s digital infrastructure was designed for such submissions and rejecting them defeats the purpose of e-governance.
For the Respondent
The respondent did not advance any substantive legal argument against the petitioner’s reliance on precedent. The Additional Government Pleader merely asserted that the application was not processed due to internal administrative confusion, without citing any rule or notification that invalidated online submissions.
The Court's Analysis
The Court observed that the issue was not novel and had been conclusively resolved in two prior judgments delivered by the same bench. The refusal to accept the application was not based on any statutory prohibition but on administrative inertia. The Court held that such conduct amounted to an abuse of power and a violation of the petitioner’s right to equal treatment under Article 14.
"The State cannot remain indifferent to the digital infrastructure it has created and then deny access to citizens who have complied with its procedures."
The Court emphasized that writ jurisdiction under Article 226 is available precisely to prevent such arbitrary refusals by public authorities. It noted that the petitioner had fulfilled all formal requirements - form, fee, and mode of submission - and that the RTO’s duty was to receive and adjudicate, not to reject on speculative grounds.
The Court further held that the precedent set in A. Rajavel and W.P. No. 17275 of 2025 was binding on the same court and could not be ignored. The principle of stare decisis required uniformity in judicial direction, especially in matters of public service delivery.
The Verdict
The petitioner succeeded. The Court directed the RTO to receive the petitioner’s online application in Form CCPA and decide it on its merits within eight weeks. No costs were imposed. The judgment reinforced that administrative bodies must accept digitally submitted applications where no legal bar exists.
What This Means For Similar Cases
Online Applications Cannot Be Rejected on Technical Grounds
- Practitioners may now cite this judgment to compel RTOs and other transport authorities to accept online permit applications under Form CCPA.
- Any refusal based on "lack of familiarity" or "internal guidelines" is legally unsustainable.
- The burden shifts to the authority to prove a statutory prohibition - not to the applicant to prove permissibility.
Precedent Binding on Same Bench
- When a High Court bench has ruled on an identical issue, subsequent petitions on the same facts must be decided consistently.
- Courts will not entertain arguments that attempt to distinguish identical factual matrices.
- This strengthens the doctrine of stare decisis in administrative writs.
Digital Access Is a Constitutional Right
- The judgment implicitly recognizes digital access to public services as an extension of Article 21 rights to livelihood and equality.
- Authorities must proactively enable digital compliance, not create barriers.
- This sets a precedent for other permit systems - driver’s licenses, vehicle registrations, trade licenses - where online portals exist.
