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2026 DAILYLAW 27100 (ORI)

Nilendri Charan Sahoo v. State of Odisha

2026-01-22

Sanjeeb K Panigrahi

body2026
JUDGMENT : Sanjeeb K Panigrahi, J. 1. Since the issues raised in all the Writ Petitions referred to above involve common questions of fact and law, those were heard analogously and are being disposed of by this common judgment. For the sake of convenience and effective adjudication, W.P.(C) No.26766 of 2025 is treated as the lead case. 2. In W.P.(C) No.26766 of 2025, the Petitioner challenges the action of the Opposite Party No.2/ State Transport Authority (STA), Odisha, Cuttack in not transmitting the VCRs against the Vehicle No.OD-04-R-2027 to the court of the learned J.M.F.C. (Transport), Cuttack to dispose of the same as per law and keeping in view the judgment of this Court in Anjana Babulal Darabad – vrs.- Commissioner, STA and Ors ., 2014 SCC Online Ori 652 I. F ACTUAL M ATRIX OF THE C ASE 1. The brief facts of the case are as follows: (i) The Petitioner is the registered owner of the vehicle bearing registration No.OD-04-R-2027 and sustaining his livelihood by plying the said vehicle. While the vehicle was plying on road, the V.C.Rs bearing ChallanN0.0R7148472231120013452 dated 18.11.2023 and bearing ChallanN0.0R7148472231207034769 dated 05.12.2023 are illegally issued against the Vehicle No-OD-04-R-2027 in violation of Section 192 of the M.V. Act imposing fine Rs.5,000/- and Rs.10,000/-only. (ii) The Petitioner, through his learned Advocate, submitted a representation dated 15.09.2025 before Opposite Party No.2, praying for transmission of the relevant Vehicle Case Records (VCRs) to the Court of the learned J.M.F.C.(T), Cuttack. It is alleged that despite receipt of the said representation, Opposite Party No.2/State Transport Authority, Odisha, Cuttack, without assigning any reasons and without taking a decision thereon, has remained completely inactive. Such inaction has resulted in serious prejudice to the Petitioner, inasmuch as it has impeded the transfer of ownership of the vehicle. The Petitioner has, therefore, invoked the extraordinary jurisdiction of this Court under Articles 226 and 227 of the Constitution of India, seeking appropriate directions. II. S UBMISSIONS O N B EHALF O F T HE P ETITIONER 2. Learned counsel for the Petitioner earnestly made the following submissions in support of his contentions: (i) The Petitioner had no knowledge of the aforesaid Vehicle Check Reports (VCRs) at the time when he applied for transfer of ownership of the vehicle. II. S UBMISSIONS O N B EHALF O F T HE P ETITIONER 2. Learned counsel for the Petitioner earnestly made the following submissions in support of his contentions: (i) The Petitioner had no knowledge of the aforesaid Vehicle Check Reports (VCRs) at the time when he applied for transfer of ownership of the vehicle. It was only thereafter that the Petitioner came to know that certain challans pertaining to the said vehicle had been pending since the year 2023, on account of which the transfer of ownership could not be effected. (ii) Contending that the aforesaid Vehicle Check Reports (VCRs) have been illegally drawn in respect of his vehicle, the Petitioner promptly submitted a representation/application dated 15th September, 2025 before the issuing authority, namely the State Transport Authority (STA), Cuttack, praying for transmission of the said VCRs to the Court of the learned J.M.F.C., Cuttack for disposal in accordance with law. It is alleged that despite receipt of the said representation, the concerned authority has failed to take any action thereon and has remained inactive, thereby causing continuing prejudice to the Petitioner. (iii) It is further submitted that Rule 167 of the Central Motor Vehicles Rules, 1989 mandates that upon issuance of a challan, the issuing authority shall serve the same upon the registered owner of the vehicle either through physical means or by electronic communication, and shall take steps for its disposal within a period of ninety days. In the event the challan is not disposed of within the stipulated period, the Rule contemplates issuance of a reminder to the vehicle owner, followed by regulatory measures, including stoppage of certain documentary services as envisaged under sub- rule (7) of Rule 167, and, in appropriate cases, detention of the vehicle so as to compel compliance. (iv) In the present case, it is contended that no action whatsoever was taken by the issuing authority in terms of the aforesaid statutory scheme during the period 2023 to 2025 for disposal of the impugned VCR challans. In the counter affidavit, Opposite Party No.2 has asserted that intimation of the challans was duly communicated to the Petitioner through SMS on the registered mobile number. The Petitioner, however, disputes such assertion and contends that upon verification, no such SMS intimation was ever received. In the counter affidavit, Opposite Party No.2 has asserted that intimation of the challans was duly communicated to the Petitioner through SMS on the registered mobile number. The Petitioner, however, disputes such assertion and contends that upon verification, no such SMS intimation was ever received. It is further submitted that the Petitioner became aware of the pendency of the challans only at the stage when he applied for transfer of ownership of the vehicle, whereupon the existence of the pending VCRs came to light. It is further submitted that on the representation filed by the Petitioner the Opposite Party/ STA stated in the counter affidavit that the owner/violator has a legal right to contest the case before the appropriate court within ninety days, no legal right to contest before the court subsisting after expiry of the limitation prescribed for taking cognizance of offence by the learned Trial Court. Therefore, beyond the period of limitation is not at all entertainable. In this regard, it is further contended that the Opposite Party/ STA cannot take advantage of his own wrong. (v) It is also submitted that there is no clear provision in Rule 167, or in Central Motor Vehicle Rule or in M.V. Act that when or in which situation or in which period the challans will be sent to the court for disposal. Hence, the statement of Opposite Party/ STA that Petitioner has to pursue the legal right to contest the offence after ninety days from the issuance of challan is not correct. Moreover, in order to overcome such type of situation, this Court has been pleased to direct in Anjana Babulal Darabad (supra) directing the Officers of O.M.V.D. that if the vehicle owner/violator fails to compound the offences on payment of prescribed fine Online or Offline within fifteen days from the date of issuance of challan, VCR issuing officer will submit prosecution report before the court having jurisdiction, namely, Transport Magistrate/J.M.F.C./S.D.J.M. for disposal of the VCR within fifteen days from the date on which compounded fine was to be paid. The order of this Court in Anjana Babulal Darabad (supra) has been quoted below: “(i) In view of the aforesaid discussion and finding arrived at by this Court, the writ petitions as against the VCRs is not maintainable and parties are to exhaust the remedies under the provisions of the M. V. Act and Rules framed thereunder. The order of this Court in Anjana Babulal Darabad (supra) has been quoted below: “(i) In view of the aforesaid discussion and finding arrived at by this Court, the writ petitions as against the VCRs is not maintainable and parties are to exhaust the remedies under the provisions of the M. V. Act and Rules framed thereunder. (ii) The VCRs issued prior to 2010 which are pending, the same should be dropped as it is hit by the provisions contained in Section 468of the Cr.P.C. (iii) Pending VCRs with effect from 2011 onwards, should be considered in the light of the circular issued on 09.12.2013 bearing circular No.3 of2013 read with Gazette Notification No.1l5ldated29.09.1995, issued under section 200 of the M.V. Act, 1988. (iv) The State Government is directed to consider the recommendation of the Transport Commissioner- cum- Chairman, State Transport Authority, Orissa, Cuttack and lay down the procedures, in respect of VCRs which are pending after 2011 as expeditiously as possible. (v) Pending such approval, direction is hereby given to the OMVD Officers issuing the VCR to direct the driver/owner/person in possession and control of motor vehicle either compound the offence on payment of prescribed fine offline/online or to appear before the STA/RTA and produce the demanded documents for disposal of VCR within fifteen days, failing which the VCR issuing officer will submit prosecution report before the court having jurisdiction, namely, Transport Magistrate J.M.F.C./ S.D. J.M. for adjudication of the VCR within fifteen days from the date on which compounded fine was to be paid. The Transport Magistrate/ JMFC/SDJM may allow compounding of the offences, strictly in conformity with the Gazette Notification No.1151 dated29.09.1995.As prescribed under Rule 139 of C.M.V. Rules, 1989, the owners/ driver/ conductor may also send Xerox copy of R.C./I.C./Permit/D.L. and any other relevant documents duly attested by Police Officer or any other officer to the officer who demanded the documents by registered post within fifteen days from the date of issue of VCR.” (vi) It is submitted that neither the Motor Vehicles Act, 1988 nor the Central Motor Vehicles Rules, 1989 prescribes a specific time frame for transmission of Vehicle Check Reports (VCRs) to the jurisdictional court. In the absence of an express statutory mandate, this Court, in Anjana Babula Darabad (supra), has laid down a procedural framework to govern such transmission, which is binding on the authorities. In the absence of an express statutory mandate, this Court, in Anjana Babula Darabad (supra), has laid down a procedural framework to govern such transmission, which is binding on the authorities. The failure of the Opposite Party to adhere to the said judicially evolved procedure constitutes a clear dereliction of public duty. (vii) The record further discloses that the Opposite Party/State Transport Authority has neither initiated steps for disposal of the VCRs in accordance with Rule 167 of the Central Motor Vehicles Rules, 1989, nor did they transmit the VCRs to the competent court in compliance with the directions of this Court. Such prolonged and unexplained inaction amounts to manifest arbitrariness and administrative indifference, falling foul of the mandate of Article 14 of the Constitution of India, which proscribes arbitrary State action. (viii) The Petitioner, having complied with the statutory framework and having approached the authority within a reasonable time, was legitimately entitled to expect that the Opposite Party would act in a fair, timely, and legally compliant manner. The doctrine of legitimate expectation, which is an integral facet of Article 14 jurisprudence, stands squarely attracted in the present case. The frustration of such expectation due to the inaction of the authority cannot be countenanced in law. (ix) Further, the lapse of the period for taking cognizance is a direct consequence of the Opposite Party’s failure to discharge its statutory and judicially mandated obligations. The Petitioner cannot, in all fairness, be placed in a position of prejudice or disadvantage for an omission solely attributable to the State. In order to permit such an approach would be to legitimize arbitrariness and penalize a citizen for no fault of his own. It is further contended that there is a no specific mention in Rule 167 of the CMVR, 1989 that the petitioner/vehicle owner/violater will come forward to close the VCR within ninety days unless he will be responsible for bar of limitation for taking cognizance. On the other hand, it has been mentioned that all steps will be taken by the Opposite Party/ issuing authority to dispose of the VCR. On the other hand, it has been mentioned that all steps will be taken by the Opposite Party/ issuing authority to dispose of the VCR. Also, direction has been made by this Court to the Opposite Party/issuing authority to send the VCR to the court within 15 days, if it is not compounded on payment but not to the Petitioner/vehicle owner that he should make application within a certain period to the issuing authority to send the VCR to the court having jurisdiction. So, the statement of the Opposite Party that the prayer for transmitting the VCR to the appropriate court beyond the period of limitation by the Petitioner is not at all correct. (x) In the aforesaid premises, it is prayed that this Court may be pleased to allow the writ petition by issuing an appropriate writ of mandamus directing the Opposite Party/State Transport Authority to forthwith transmit the challans issued in respect of the Petitioner’s vehicle to the jurisdictional Court for disposal in accordance with law, within a stipulated time frame. It is further prayed that, upon such transmission or pending disposal of the challans, the Petitioner may not be deprived of effecting the transfer of ownership of the vehicle, and the competent authority be directed to process and facilitate the said transfer strictly in accordance with law, without being influenced by the pendency occasioned due to the inaction of the Opposite Party. III. S UBMISSIONS O N B EHALF O F T HE O PPOSITE P ARTIES 3. The Learned Counsel for the Opposite Parties earnestly made the following submissions in support of his contentions: (i) Admittedly, the aforesaid e-challans were generated through electronic devices installed by the Transport Authorities with the object of curbing traffic violations and promoting road safety. It is also not in dispute that all such e-challans pertain to alleged violations committed more than one year prior to the approach made to this Court seeking their transmission to the jurisdictional Magistrate for trial or disposal. (ii) It is further contended that despite intimation through electronic modes, the Petitioners in the above-mentioned writ petitions did not compound the offences within the time stipulated under Rule 167 of the Motor Vehicles Rules. (ii) It is further contended that despite intimation through electronic modes, the Petitioners in the above-mentioned writ petitions did not compound the offences within the time stipulated under Rule 167 of the Motor Vehicles Rules. It is urged that transmission of a Vehicle Check Report (VCR) to the jurisdictional Magistrate after the expiry of the period of limitation would be an exercise in futility, inasmuch as the Court would be legally precluded from proceeding further in view of the bar of limitation prescribed under Section 514 of the Bharatiya Nagarik Suraksha Sanhita, 2023.It is a settled principle that no writ of mandamus can be issued to compel an authority to perform an act which is contrary to law or serves no legal purpose. (iii) He further submitted that since a comprehensive statutory mechanism provided under the Motor Vehicles Act, 1988 and the Rules framed thereunder, read with the bar of limitation, the present Writ Petition under Articles 226 and 227 of the Constitution of India may not be maintainable. (iv) Insofar as the reliance placed by the Petitioner on the judgment in Anjana Babulal Darabad (supra) is concerned, such reliance is out and out misplaced. A careful reading of the said decision, on the contrary, reinforces the position that the statutory remedies provided under the governing framework are required to be availed within the prescribed time. The said judgment does not dilute the statutory scheme, rather underscores the obligation of the parties to adhere to the timelines contemplated therein, which supports the stand taken by the Opposite Parties herein. The petitioner, having failed to act within the statutory period, cannot take advantage of his own inaction. Equity does not operate in favour of a party who has slept over his rights. The relevant Rules have been quoted hereunder: Central Motor Vehicles Rules, 1989 “Rule.2(ca) defines challan as under: (ca) ‘Challan’ means a document, in physical or electronic form issued by any police officer in uniform or any other officer authorized by the State Government in this behalf, to a person acting in violation of the provisions of the Act, in the form of a receipt comprising the details of the offence committed and the offender, the amount of penalty imposed and mode of collection of the same, if applicable, details of the officer issuing such document and other details as may be specified by the State Government. Explanation-F or the purposes of this clause, E-challan shall mean a challan issued in electronic form.;” Rule-167 of CMV Rules, 1989 provides as under : “ Rule-167.Procedure for issuance and payment of challan .-(l)Any police officer in uniform or any other officer, authorized by the State Government in this behalf shall issue a challan through system or e-challan facility physical or electronic form, to a person acting in violation of the provisions of the Act. (2) Notwithstanding anything contained in sub-rule (l) incased of any person violates the provisions of the Act, the State Government or designated agency can enable auto-generation of challan through electronic monitoring and enforcement system or manually by any police officer or by a designated agency. (3) The challan issued under sub-rule (l) or (2), shall be delivered to a person who violates the provisions of the Ac either by hand or any other physical or electronic means of communication authorized by the Central Government or State Government. (4) Details of challans issued under sub-rule (l) or (2),shall be recorded chronologically in the portal on a regular basis for access by enforcement officers. (5) Challans issued under sub-rule (l) or (2) shall be disposed of within ninety days from the date of issuance of the challan, in physical or electronic form, except in case of offences instituted for prosecution by a Court. (6) If a challan is due beyond the time period specified in sub-rule (5), at least one additional notice for payment may be sent through electronic means of communication authorised by the Central Government or State Government or by way of call to the registered mobile number of a person who violates the provisions of the Act. (7) If a challan is due beyond the time period specified in sub-rule (5), except in case of offences instituted for prosecution by a Court then applications with respect to the license of offender or registration of motor vehicle, as the case may be, mentioned in the challan shall not be processed by the licensing authority or registering authority, as the case may be, except applications relating to permit, fitness and tax of motor vehicle. (8) Subject to orders of the Court in respect of challans issued under sub-rule (1) or (2), a police officer in uniform authorized by the State Government in this behalf may detain the vehicle involved in violation. (8) Subject to orders of the Court in respect of challans issued under sub-rule (1) or (2), a police officer in uniform authorized by the State Government in this behalf may detain the vehicle involved in violation. Rule-167-A provides as under : “ 167-A. Electronic Monitoring and Enforcement of Road Safety - (l) The electronic enforcement device used for issuance of a challan shall have and approval certificate signed by a designated authority of the State Government certifying that the device is accurate and operating properly and the approval certificate shall be renewed on a yearly basis. Explanation-(l) For the purpose of this rule, “electronic enforcement device”" means a speed camera, closed-circuit television camera, speed gun, body wearable camera, dashboard camera, Automatic Number Plate Recognition (ANPR), weight in machine (WIM) and any such other technology specified by the State Government. (2) But wearable camera may be worn by police officer, transport official or any other official auhorised by the State Government and such officer or official shall notify to the offender that he is being recorded by the body camera and similarly, dashboard camera may be placed on the dashboard of any police vehicle or in any other vehicle as authorised by the State Government for enforcing the traffic rules and such officer or official shall notify to the offender that he is being recorded by the dashboard camera. (2) State Governments shall ensure that appropriate electronic enforcement devices are placed at high risk and high density corridors on National Highways and State Highways, and at critical junctions at least in major cities with more than one million population (as per data available based on Million plus Urban Agglomerations or Cities : census of India 2011 or as per the latest census) including the 132 cities as specified in the table below, and the electronic enforcement device shall be placed in such a manner so as not to cause any obstruction, line of sight issues or interruption in traffic flow.” (v) With reference to Section 200 of the Motor Vehicles Act, it is submitted that the discretion vested therein is neither unguided nor uncanalised, nor does it suffer from arbitrariness. The statutory scheme makes it abundantly clear that compounding of an offence under the said provision is conditional upon the voluntary willingness of the accused, and cannot be imposed as a matter of right or compulsion. The statutory scheme makes it abundantly clear that compounding of an offence under the said provision is conditional upon the voluntary willingness of the accused, and cannot be imposed as a matter of right or compulsion. In support of the said contention, learned counsel for the Opposite Parties has placed reliance on the judgment of the Supreme Court in P. Ratnakar Rao and others -vrs.- Govt.of AP and others , (1996)5 SCC 359 (vi) In view of Rule 167(5) of the Central Motor Vehicles Rules, 1989, the statutory scheme contemplates that an e-challan is ordinarily required to be dealt with within a period of ninety days. Consequently, the option available to the accused/violator, either to compound the offence or to contest the allegation by facing trial, ought to be exercised within the said statutory framework and time period, failing which the matter attracts the consequences envisaged under the Rules. (vii) This Court in earlier Judgment in Anjana Babulal Dorabad (supra) in Paragraph-18 has held as under : “18. Considering the above provisions of law, since the penalty under the M.V. Act varies from six months to three years, in respect of vehicle checking reports issued for offences where the maximum punishment that can be imposed is three years but in the meantime that period has already been over, forwarding such VCRs to the Magistrate, would be hit by Section 468 of the Cr.P.C.. Therefore, no useful purpose can be served if at this stage the matter is directed to be tried by the Court having jurisdiction over the same. So far as the matters which are pending within three years, in which cases, it has been indicated in the vehicle checking reports to the concerned STA/RTA on a particular dale, but the said date has already been over, it appears that the concerned STA/RTA instead of sending the matter to the concerned Court having jurisdiction, are sitting tight over the same as a result no steps could be taken by the concerned Court. On the other hand, it by filing the writ petitions, thereby, there is a non-adherence to the provisions of the M.V. Act and Rules framed thereunder.” (viii) Accordingly, this Court has ultimately directed as under: “(i) In view of the aforesaid discussion and finding arrived at by this Court, the writ petition as against the VCRs is not maintainable and parties are to exhaust the remedies under the provisions of the M.V. Act and Rules framed thereunder. (ii) The VCRs issued prior to 2010 which are pending, the same should be dropped as it is hit by the provisions contained in Section 468 of the Cr.P.C. (iii) Pending VCRs with effect from 2011 onwards, should be considered in the light of the circular issued on 9.12.2013bearing circular No.3 of 2013 read with Gazette Notification No.1151 dated 29.09.1995, issued under Section 200 of the M.V. Act, 1988. Xx xx xx xx xx” (ix) In view of Rule 167(6) of the Central Motor Vehicles Rules, 1989, the recourse available to the competent authority, in cases where an e- challan remains pending beyond the stipulated period, is confined to withholding registration- and licence-related services during the subsistence of such pendency. The said Rule does not contemplate transmission of the e-challan to the Court as a matter of course. Transmission to the jurisdictional Magistrate is envisaged only in a situation where the offender expresses unwillingness to compound the offence in accordance with the statutory scheme. (x) Section 519 of the BNSS, 2023 empowers the court to extend the period of limitation if it is necessary to do in the interest of justice. Section 519 ofBNSS,2023 is reproduced asunder:- “519. Extension of period of limitation in certain cases- Notwithstanding anything contained in the foregoing provisions of this Chapter, any Court may take cognizance of an offence after the expiry of the period of limitation, if it is satisfied on the facts and in the circumstances of the case that the delay has been properly explained or that it is necessary so to do in the interest of justice.” (xi) The overarching objective underlying the provisions of the Motor Vehicles Act, 1988 and the Rules framed thereunder is to promote road safety, ensure regulatory compliance, and prevent road accidents, rather than to create punitive impediments divorced from the purpose of the statute. The observations of the Supreme Court in Rattan Singh vs. State of Punjab , (1979) 4 SCC 719 are symbolic of the malady that has crept into use of public roads and the present situation is grave. Further, the Supreme Court in case of S. Rajaseekaran vs. Union of India , (2014) 6 SCC 36 has established a mechanism for implementation and enforcement of road safety which shapes the road safety framework (xii) In view of the aforesaid object of enforcing road safety and ensuring regulatory compliance, it is contended that, should this Court be inclined to allow the prayer of the Petitioners, the jurisdictional Magistrate may be directed to consider, in accordance with law, the question of extension of limitation, if permissible, upon being satisfied that such extension is expedient in the interest of justice, and thereafter to proceed to take cognizance of the alleged offence in accordance with law. IV. J UDGMENT AND ANALYSIS 4. Heard counsel for the parties and perused the documents placed on record including the counter affidavit of the Transport Department. i. At the outset, this Court considers it necessary to delineate the contours of its jurisdiction under Articles 226 and 227 of the Constitution of India in matters arising from statutory enforcement regimes. It is a settled principle of constitutional law that while the writ jurisdiction is wide, it is not unbounded. The power under Article 226 is discretionary, equitable, and supervisory in nature, and is ordinarily not exercised where the field is occupied by a comprehensive statutory framework providing for rights, obligations, remedies, and consequences. ii. Judicial intervention, particularly by way of mandamus, is therefore conditioned by the existence of a legally enforceable right and a corresponding public duty, both of which must subsist at the time relief is sought. The Motor Vehicles Act, 1988, read with the Central Motor Vehicles Rules, 1989, constitutes a self-contained regulatory code governing road safety, detection of traffic violations, imposition of penalties, compounding of offences, and initiation of prosecution. The statutory architecture does not treat traffic violations as ordinary private disputes but as regulatory infractions impacting public safety. The emphasis of the legislation is preventive and deterrent rather than retributive, a feature repeatedly underscored by constitutional courts while interpreting road safety legislation. iii. The statutory architecture does not treat traffic violations as ordinary private disputes but as regulatory infractions impacting public safety. The emphasis of the legislation is preventive and deterrent rather than retributive, a feature repeatedly underscored by constitutional courts while interpreting road safety legislation. iii. Rule 167 of the Central Motor Vehicles Rules, 1989 provides a complete procedural mechanism for issuance, service, and disposal of challans, including electronically generated e-challans. Sub-rules (5) to (7) reflect a clear legislative intent i.e. challans are to be disposed of within a defined time frame, and where they remain unpaid, regulatory consequences such as withholding of registration or licence-related services are to follow. Significantly, the Rule does not mandate automatic prosecution or mechanical transmission of every challan to a criminal court. Prosecution is an exception within the scheme, not the rule, and is envisaged primarily where compounding is declined or where the offence is of such gravity as to warrant judicial adjudication. iv. This statutory design assumes significance when examined in light of the law of limitation governing criminal proceedings. Section 514 of the Bharatiya Nagarik Suraksha Sanhita, 2023 embodies a legislative policy that minor offences should not remain indefinitely alive. Limitation provisions in criminal law are not mere technicalities rather they are founded on public policy considerations that recognize the diminishing utility and fairness of stale prosecutions. Once the statutory period expires, the jurisdiction of the criminal court itself stands curtailed, subject only to the limited and judicially controlled power of extension under Section 519 BNSS. v. In this backdrop, the relief sought by the Petitioner, namely, a direction to the Transport Authority to transmit VCRs to the Magistrate after expiry of the limitation period raises a fundamental jurisprudential concern. A writ of mandamus cannot be issued to compel an authority to perform an act which the law either does not contemplate or which would be rendered legally infructuous. vi. Courts while exercising constitutional jurisdiction do not issue directions in vacuum, rather they act to enforce law, not to bypass it. In order to direct transmission of VCRs where cognizance itself may be barred would be to command an act that the criminal court may be legally disabled from acting upon. vii. The argument that administrative inaction should not prejudice the citizen is, in principle, unexceptionable. Administrative law has consistently held that the State cannot take advantage of its own wrong. In order to direct transmission of VCRs where cognizance itself may be barred would be to command an act that the criminal court may be legally disabled from acting upon. vii. The argument that administrative inaction should not prejudice the citizen is, in principle, unexceptionable. Administrative law has consistently held that the State cannot take advantage of its own wrong. However, this principle cannot be applied in isolation or in a manner that defeats express statutory mandates. Where the legislature has prescribed a limitation on judicial power itself, constitutional equity cannot be invoked to resurrect jurisdiction that has statutorily lapsed. The doctrine that “equity follows the law” retains full force in such situations. viii. The reliance placed on Anjana Babulal Darabad(supra) requires careful contextual reading. That decision, far from conferring an open- ended right upon vehicle owners to demand prosecution at any stage, emphasized three core principles: first, that writ petitions challenging VCRs are ordinarily not maintainable; second, that statutory remedies must be exhausted within the prescribed framework; and third, that revival of time-barred proceedings serves no useful purpose. The procedural directions issued therein were situational, aimed at streamlining enforcement during a transitional phase, and cannot be elevated to override the statutory scheme or the law of limitation. ix. The Court is equally mindful of the constitutional mandate under Article 14, which prohibits arbitrary State action and undergirds the doctrine of legitimate expectation. Undoubtedly, citizens are entitled to expect fair, timely, and reasonable administrative conduct. However, legitimate expectation does not create a substantive right contrary to statute; it operates within the boundaries of law. Where the legislature itself has circumscribed the consequences of delay and provided regulatory, rather than prosecutorial, responses to non- payment of challans, the doctrine cannot be invoked to compel prosecution beyond limitation. x. From a broader jurisprudential perspective, the object of road safety legislation cannot be lost sight of. The Supreme Court has repeatedly emphasized that traffic regulation is an area where strict enforcement, swift disposal, and certainty of consequence are essential to deterrence. Allowing stale challans to be resurrected through writ proceedings would undermine both administrative discipline and judicial power, while contributing little to the cause of road safety. The statutory scheme consciously avoids such an outcome by providing administrative consequences in lieu of delayed prosecutions. xi. Allowing stale challans to be resurrected through writ proceedings would undermine both administrative discipline and judicial power, while contributing little to the cause of road safety. The statutory scheme consciously avoids such an outcome by providing administrative consequences in lieu of delayed prosecutions. xi. At the same time, this Court is conscious that Section 519 BNSS preserves a narrow judicial discretion in the Magistrate to extend limitation where the interests of justice so demand. That discretion, however, is to be exercised on a case-by-case basis, upon judicial satisfaction, and cannot be pre-empted or directed by a writ court. The constitutional court’s role ends at ensuring that such discretion remains available in law and it cannot dictate its exercise. xii. In view of the above, the present case does not disclose a jurisdictional error, manifest illegality, or constitutional violation warranting interference under Articles 226 or 227. The grievance projected, though not devoid of sympathy, falls within the domain of statutory consequences rather than constitutional correction. Judicial restraint, in such circumstances, is not abdication but fidelity to the separation of powers and legislative intent. xiii. The above analysis, in essence, leads to the conclusion that while administrative authorities are expected to act with diligence and promptitude, constitutional writ jurisdiction cannot be employed to revive time-barred statutory processes, compel futile acts, or override express legislative policy. Any other approach would risk converting equitable jurisdiction into a mechanism for unsettling settled law. V. C ONCLUSION : 5. For the reasons discussed hereinabove, this Court is of the considered view that the Motor Vehicles Act, 1988 and the Central Motor Vehicles Rules, 1989 constitute a comprehensive and self-contained statutory framework governing the issuance, disposal, and consequences of Vehicle Check Reports and e-challans. The scheme of the legislation, read purposively, does not contemplate mechanical or indefinite prosecution of traffic violations, particularly where the statutory period for taking cognizance has elapsed and regulatory consequences have been expressly provided in substitution thereof. 6. While administrative authorities are undoubtedly under a public duty to act with promptitude and fairness, the failure or delay on their part cannot, by itself, furnish a basis for invoking the extraordinary writ jurisdiction to compel acts which are either not mandated by statute or which would be rendered legally ineffectual by the bar of limitation. 6. While administrative authorities are undoubtedly under a public duty to act with promptitude and fairness, the failure or delay on their part cannot, by itself, furnish a basis for invoking the extraordinary writ jurisdiction to compel acts which are either not mandated by statute or which would be rendered legally ineffectual by the bar of limitation. Constitutional remedies under Articles 226 and 227 are designed to enforce the law, not to circumvent express legislative commands or revive jurisdiction that has statutorily lapsed. 7. The reliance placed on earlier judicial directions cannot be construed as creating an indefeasible right of the vehicle owner to demand prosecution at any stage, irrespective of statutory limitation. Nor can doctrines of arbitrariness or legitimate expectation be pressed into service to override the clear contours of the statutory scheme. Equity must operate within the framework of law and cannot supplant it. 8. Accordingly, this Court holds that no case is made out for the issuance of a writ of mandamus directing transmission of the impugned Vehicle Check Reports to the criminal court. It is, however, clarified that this conclusion shall not preclude the competent Magistrate, if approached in accordance with law, from independently considering the question of extension of limitation under the relevant statutory provision, strictly on its own merits and in the interest of justice. 9. The W.P.(C) No.26766 of 2025, therefore, stands disposed of in the above terms. Accordingly, all the connected Writ Petitions are disposed of. 10. Interim order, if any, passed earlier in any of the aforesaid Writ Petitions stands vacated.