- 1 - HC-KAR NC: 2026:KHC:32988 WP No. 19646 of 2022 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 2ND DAY OF JULY, 2026 BEFORE THE HON'BLE MR. JUSTICE B M SHYAM PRASAD WRIT PETITION NO. 19646 OF 2022 (LB-TAX) BETWEEN: 1. RUKMINI EDUCATIONAL CHARITABLE TRUST HAVING REGISTERED OFFICE DIVYASHREE CHAMBERS A WING NO.11 O SHAUGNESSY ROAD BANGALORE-560025 REPRESENTED BY ITS CHAIRMAN AND MANAGING TRUSTEE. 2. REVA UNIVERSITY HAVING REGISTERED ADDRESS AT RUKMINI KNOWLEDGE PARK YELAHANKA, BENGALURU-560064 REPRESENTED BY ITS CHANCELLOR. …PETITIONERS (BY SRI. MANU K.,ADVOCATE) AND: 1. THE STATE OF KARNATAKA DEPARTMENT OF URBAN DEVELOPMENT M S BUILDING, DR AMBEDKAR ROAD, Digitally signed by VANAMALA N Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2026:KHC:32988 WP No. 19646 of 2022 BANGALORE-560001 REPRESENTED BY ITS PRINCIPAL SECRETARY. 2. BRUHAT BENGALURU MAHANAGARA PALIKE HAVING HEAD OFFICE AT HUDSON CIRCLE BENGALURU, KARNATAKA-560002 REPRESENTED BY ITS COMMISSIONER. …RESPONDENTS (BY SRI.BOPANNA BELLIAPPA., AGA FOR R1; SRI. B.V. MURALIDHAR., ADVOCATE FOR R2) THIS WP IS FILED UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA PRAYING TO DECLARE THAT SECTION 152(1)(b) OF THE BRUHAT BANGALORE MAHANAGARA PALIKE ACT 2020 IS ULTRA VIRES AND VIOLATIVE OF ARTICLE 14 OF THE CONSTITUTION IN SO FAR AS IT IMPOSES PROPERTY TAX ON PRIVATE EDUCATIONS INSTITUTIONS ESTABLISHED AND ADMINISTERED WITHIN BBMP AREA;QUASH THE CIRCULAR DATED 29.03.2021 BEARING NO.JA.AA(KAM)PR 2607.2020.21 ISSUED BY THE R2 BBMP AND PRODUCED AS ANNEXURE-J; SET ASIDE THE DEMAND NOTICE ISSUED ON P1 AND PRODUCED - 3 - HC-KAR NC: 2026:KHC:32988 WP No. 19646 of 2022 AS ANNEXURE-L; DIRECT THE R2 TO REIMBURSE THE EXCESS COMPONENT OF THE PROPERTY TAX PAID BY THE P1 VIDE BBMP APPLICATION NO.1600644114 PRODUCED AS ANNEXURE-K AFTER DEDUCTING THE 25 PERCENT SERVICE CHARGE APPLICABLE UNDER BBMP PROPERTY TAX RULES 2009; DIRECT THE R2 TO ADJUST THE EXCESS AMOUNT PAID BY THE PETITIONER TO THE ACCOUNT OF THE R2 VIDE ANNEXURE-K TOWARDS THE 25 PERCENT SERVICE CHARGE THAT WILL ACCRUE FOR PAYMENT BY THE PETITIONER TO THE R2 FOR THE CURRENT YEAR 2022.23 AND SUBSEQUENT YEARS UNTIL THE AFORESAID EXCESS AMOUNT STAND ADJUSTED COMPLETELY AND TO ISSUE RECEIPTS FOR THE SAME TO THE PETITIONERS BEFORE THE EXPIRY OF THE DUE DATE FOR PAYMENT OF SUCH TAXES. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE B M SHYAM PRASAD - 4 - HC-KAR NC: 2026:KHC:32988 WP No. 19646 of 2022 ORAL ORDER The question presented for consideration by the petitioners in this petition is about the permissibility of calling upon educational institutions to pay Property Tax. The petitioners have called in question the Demand Notice dated Nil [Annexure-L] and seeking reimbursement of the taxes already paid. However, it is undisputed that the State Government has amended the provisions of the Bruhat Bengaluru Mahanagara Palike Act, 2020 which exempted certain educational institutions from payment of Property Tax, and in fact, similar petitions have been disposed of quashing the demand and observing that any amount of 25% as services shall be adjusted towards future charges. A copy of the order dated 17.04.2023 in the writ petition in W.P. No.12954/2021 is placed on record. As such, upon hearing Sri Manu K, the learned counsel for the petitioners, and Sri B V Muralidhar, - 5 - HC-KAR NC: 2026:KHC:32988 WP No. 19646 of 2022 the learned counsel for the second respondent, the impugned Demand [Annexure-L] would call for interference. Insofar as the petitioners' request for reimbursement is concerned, the payment made in excess shall be adjusted towards future demands for service charges. Hence the following: ORDER The petition is allowed-in-part quashing the impugned Demand Nil [Annexure-L] observing that the payment made in excess shall be adjusted towards future service charges. SD/- (B M SHYAM PRASAD) JUDGE AN/-