Motilal Padampat Sugar Mills Co Ltd v State of Uttar Pradesh
- Facts
- UP Government represented that new industrial units would receive a three-year sales tax exemption. Motilal Padampat Sugar Mills set up a new unit in reliance on the representation.
- Issue
- Are the elements of promissory estoppel satisfied?
- Held
- Bhagwati J: all four elements satisfied. Government bound for the three-year period. Revenue shortfall and policy change do not constitute supervening public interest. The government must disclose the specific genuine and pressing public interest reason to the court; it cannot simply assert override.
- Principle
- Promissory estoppel against government: four elements (clear representation, intended reliance, actual reliance, detriment); overrideable only by demonstrated supervening public interest disclosed to court.
Facts
- UP Government represented that new industrial units would receive a three-year sales tax exemption
- Motilal Padampat Sugar Mills set up a new unit in reliance on the representation
- Government withdrew the exemption before three years had elapsed citing revenue considerations and policy change
Issues
- Are the elements of promissory estoppel satisfied?
- Can the government withdraw citing revenue considerations?
- What standard governs the public interest override?
Held
- Bhagwati J: all four elements satisfied. Government bound for the three-year period. Revenue shortfall and policy change do not constitute supervening public interest. The government must disclose the specific genuine and pressing public interest reason to the court; it cannot simply assert override.
Ratio decidendi
The definitive Indian statement on promissory estoppel against the government. Elements: (1) clear and unambiguous representation; (2) made with intention that it be acted upon; (3) actually acted upon; (4) detriment. Override only on genuine, pressing, disclosed supervening public interest. The government cannot defeat reasonable expectations formed by reliance on its solemn representations.
Exam use
How to use it in an answer
Leading case on promissory estoppel in Indian administrative law. Apply: state four elements, apply to facts, address public interest override standard. Bhagwati J ratio is exam-quotable. Distinguish from Anglo Afghan Agencies (1968) which established the principle; Motilal Padampat systematised it.
Cite this
Citation
Motilal Padampat Sugar Mills Co Ltd v State of Uttar Pradesh AIR 1979 Supreme Court 621Reported: AIR 1979 Supreme Court 621. This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.