08 July 2010
Supreme Court
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TRANSMISSION CORP.OF A.P LTD. Vs SAI R.P.PVT. LTD. .

Bench: B.S. CHAUHAN,SWATANTER KUMAR, , ,
Case number: C.A. No.-002926-002926 / 2006
Diary number: 17123 / 2006
Advocates: A. SUBBA RAO Vs T. V. RATNAM


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IN THE SUPREME COURT OF INDIA

CIVIL APPELLATE JURISDICTION

CIVIL APPEAL NO. 2926 of 2006

Transmission Corporation of  Andhra Pradesh Ltd. & Anr.   …Appellants

Versus

Sai Renewable Power Pvt. Ltd. & Ors.           …Respondents

WITH

CIVIL APPEAL NO.5940 OF 2006

A.P. Transco     …Appellant

Versus

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2

M.S. Biomass Energy Developers  Association & Ors.         …Respondents

WITH

CIVIL APPEAL NO. 5941 OF 2006   

Transmission Corporation of  Andhra Pradesh Ltd. & Ors.    …Appellants

Versus

Small Hydro Power Developers  Association & Ors.      …Respondents

WITH  

CIVIL APPEAL NO. 5942 OF 2006

Transmission Corporation of  Andhra Pradesh Ltd. & Ors.    …Appellants

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3

Versus

K.M. Power Pvt. Ltd. & Ors. …Respondents

WITH

CIVIL APPEAL NO. 5943 OF 2006  

Transmission Corporation of  Andhra Pradesh Ltd. & Ors.    …Appellants

Versus

Manihamsa Power Projects Ltd. & Ors. …Respondents

WITH

CIVIL APPEAL NO. 5944 OF 2006

Transmission Corporation of  Andhra Pradesh Ltd. & Ors.    …Appellants

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4

Versus

PMC Power Pvt. Ltd. & Ors.    …Respondents

WITH CIVIL APPEAL NO. 5945 OF 2006  

Transmission Corporation of  Andhra Pradesh Ltd. & Ors.    …Appellants

Versus

Bhavani Hydro Power Projects Pvt. Ltd. & Ors.    …Respondents

      WITH

CIVIL APPEAL NO. 5946 OF 2006  

Transmission Corporation of  Andhra Pradesh Ltd. & Ors.    …Appellants

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Versus

NCL Energy Ltd. & Ors. …Respondents

WITH

CIVIL APPEAL NO. 5947 OF 2006

A.P. Transmission Corporation Ltd. …Appellant

Versus

M/s Active Power Corporation  Pvt. Ltd. & Ors.   ...Respondents

WITH

CIVIL APPEAL NO. 5948 OF 2006

A.P. Transmission Corporation Ltd. …Appellant

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Versus

Kakatiya  Cement Sugars &  Industries Ltd. & Ors.   …Respondents

WITH

CIVIL APPEAL NO. 5949 OF 2006

Transmission Corporation of  Andhra Pradesh Ltd. & Ors.    …Appellants

Versus

Kallam Spinning Mills Ltd. & Ors.   …Respondents

WITH

CIVIL APPEAL NO. 5950 OF 2006

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Transmission Corporation of  Andhra Pradesh Ltd. & Ors.    …Appellants

Versus

Fivess Power Projects Pvt. Ltd. & Ors.             …Respondents

WITH

CIVIL APPEAL NO. 5951 OF 2006

Transmission Corporation of  Andhra Pradesh Ltd. & Ors.    …Appellants

Versus

Srinivasa Power Projects Pvt.  Ltd. & Ors.             …Respondents

WITH

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CIVIL APPEAL NO. 5952 OF 2006

Transmission Corporation of  Andhra Pradesh Ltd. & Ors.    …Appellants

Versus

Janapadu Hydro Projects Pvt. Ltd. & Ors.             …Respondents

WITH

CIVIL APPEAL NO. 5953 OF 2006

Transmission Corporation of  

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Andhra Pradesh Ltd. & Ors.    …Appellants Versus

The South Indian Sugar Mills  Association & Ors. Respondents

WITH

CIVIL APPEAL NO. 5954OF 2006

Transmission Corporation of  

Andhra Pradesh Ltd. & Ors.   …Appellants

Versus

The South Indian Sugar Mills Association & Ors.     …Respondents

WITH

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CIVIL APPEAL NO. 5955 OF 2006

The A.P. Transmission Corporation Ltd.    …Appellant

Versus

M/s.Vensa Bio-Tek Ltd. & Ors.                     …Respondents

WITH

CIVIL APPEAL NO. 5956 OF 2006

The A.P. Transmission Corporation Ltd.    …Appellant

Versus

Sagar Sugars & Allied Products  Ltd. & Ors.            …Respondents

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WITH

CIVIL APPEAL NO. 5957 OF 2006

The A.P. Transmission Corporation Ltd.    …Appellant

Versus

M/s Raus Power Ltd. & Ors. …Respondents

WITH  

 CIVIL APPEAL NO. 5958 OF 2006

Transmission Corporation of  Andhra Pradesh Ltd. & Ors.    …Appellants

Versus

M/s Balaji Energy Pvt. Ltd. & Ors.             …Respondents WITH

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CIVIL APPEAL NO. 5959 OF 2006

Transmission Corporation of  Andhra Pradesh Ltd. & Ors.    …Appellants

Versus

Saraswati Power & Industries Pvt. Ltd & Ors.  …Respondents

WITH

CIVIL APPEAL NO. 5960 OF 2006

Transmission Corporation of  Andhra Pradesh Ltd. & Ors.    …Appellants

Versus

M/s Gayatri Sugars Limited & Ors.             …Respondents

WITH

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CIVIL APPEAL NO. 5961 OF 2006

A.P. Transco    …Appellants

Versus

Roshini Powertech Ltd. & Ors.  …Respondents

WITH

CIVIL APPEAL NO. 3091 OF 2006

Central Power Distribution Company of  Andhra Pradesh & Anr.    …Appellants

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Versus

M/s Gayatri Agro Industrial Power Ltd. & Ors.     …Respondents

WITH

CIVIL APPEAL NO. 5962 OF 2006

Eastern Power Distribution Company  of Andhra Pradesh Ltd. & Anr.    …Appellants

Versus

M/s Vamshi Industries Ltd. & Ors. …Respondents

WITH

CIVIL APPEAL NO. 5963 OF 2006

Southern Power Distribution Company of Andhra Pradesh Ltd. & Anr.    …Appellants

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Versus

M/s Matrix Power Pvt. Ltd. & Ors.                  …Respondents

WITH

CIVIL APPEAL NO. 5964 OF 2006

Northern Power Distribution Company of  Andhra Pradesh & Anr.  … Appellants

Versus

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M/s Gowthami Bio-Energies Ltd. & Ors.             …Respondents

WITH

CIVIL APPEAL NO. 3884 OF 2006

A P. Electricity Regulatory Commission    …Appellant

Versus

M/s Sia Renewable Power Pvt. Ltd. & Ors.  …Respondents

WITH

CIVIL APPEAL NO. 5966 OF 2006

A P Electricity Regulatory Commission    …Appellant

Versus

M/s Biomas Energy Developers Association & Ors. …Respondents

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WITH

CIVIL APPEAL NO. 5967 OF 2006

A P Electricity Regulatory Commission    …Appellant

Versus

Small Hydro Developers Association & Ors. …Respondents

WITH

CIVIL APPEAL NO. 5968 OF 2006

A P Electricity Regulatory Commission    …Appellant

Versus

K.M. Power Pvt. Ltd. & Ors. …Respondents

WITH

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CIVIL APPEAL NO. 5969 OF 2006

A P Electricity Regulatory Commission    …Appellant

Versus

Manihamsa Power Projects Ltd. & Ors. …Respondents

WITH

CIVIL APPEAL NO. 5970 OF 2006

A P Electricity Regulatory Commission    …Appellant

Versus

PMC Power Pvt. Ltd. & Ors. …Respondents

WITH

CIVIL APPEAL NO. 5971 OF 2006

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A P Electricity Regulatory Commission    …Appellant

Versus

Bhavani Hydro Power Projects Pvt. Ltd. & Ors. …Respondents WITH

CIVIL APPEAL NO. 5972 OF 2006

A P Electricity Regulatory Commission    …Appellant

Versus

NCL Energy Limited & Ors. …Respondents

WITH

CIVIL APPEAL NO. 5973 OF 2006

A P Electricity Regulatory Commission    …Appellant

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Versus

M/s Active Power Corporation Pvt. Ltd. & Anr. …Respondents

WITH

CIVIL APPEAL NO. 5974 OF 2006

A P Electricity Regulatory Commission    …Appellant

Versus

Kakatiya Cement Sugars & Industries Ltd. & Anr. …Respondents

WITH

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CIVIL APPEAL NO. 5975 OF 2006

A P Electricity Regulatory Commission    …Appellant

Versus

Kallam Spinning Mills Ltd. & Ors. …Respondents

WITH

CIVIL APPEAL NO. 5976 OF 2006

A P Electricity Regulatory Commission    …Appellant

Versus

Fivess Power Projects Pvt. Ltd. & Ors. …Respondents

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WITH

CIVIL APPEAL NO. 5977 OF 2006

A P Electricity Regulatory Commission    …Appellant

Versus

Srinivasa Power Projects Pvt. Ltd. & Ors. …Respondents

WITH

CIVIL APPEAL NO. 5978 OF 2006

A P Electricity Regulatory Commission    …Appellant

Versus

Janapadu Hydro Power Projects Pvt. Ltd. & Ors. …Respondents

WITH

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CIVIL APPEAL NO. 5979 OF 2006

A P Electricity Regulatory Commission    …Appellant

Versus

The South Indian Sugar Mills Association & Ors. …Respondents

WITH

CIVIL APPEAL NO. 5980 OF 2006

A P Electricity Regulatory Commission    …Appellant

Versus

The South Indian Sugar Mills Association & Ors. …Respondents

WITH

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CIVIL APPEAL NO. 5981 OF 2006

A P Electricity Regulatory Commission    …Appellant

Versus

M/s Vensa Bio-Tec Limited & Ors. …Respondents

WITH

CIVIL APPEAL NO. 5982 OF 2006

A P Electricity Regulatory Commission    …Appellant

Versus

Sagar Sugars & Allied Products Ltd. & Anr. …Respondents

WITH

CIVIL APPEAL NO. 5983 OF 2006

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A P Electricity Regulatory Commission    …Appellant

Versus

M/s Raus Power Ltd. & Anr. …Respondents

WITH

CIVIL APPEAL NO. 5984 OF 2006

A P Electricity Regulatory Commission    …Appellant

Versus

M/s Balaji Energy Pvt. Ltd. & Ors. …Respondents

WITH

CIVIL APPEAL NO. 5985 OF 2006

A P Electricity Regulatory Commission    Appellant

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Versus

Saraswati Power & Industries Pvt. Ltd. & Ors. …Respondents

WITH

CIVIL APPEAL NO. 5986 OF 2006

A P Electricity Regulatory Commission    …Appellant

Versus

M/s Gayatri Sugars Ltd. & Ors. …Respondents

WITH

CIVIL APPEAL NO. 5987 OF 2006

A P Electricity Regulatory Commission  …Appellant

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Versus

Roshni Power Tech Ltd. & Ors. …Respondents

WITH

CIVIL APPEAL NO. 3910 OF 2006

Transmission Corp of A.P. Ltd. & Ors.  …Appellants

Versus

Jeypore Sugar Company Ltd. & Anr. …Respondents

WITH

CIVIL APPEAL NO. 5988 OF 2006

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Transmission Corporation of A.P. Ltd. & Ors.    …Appellants

Versus

M/s GMR Industries Ltd. & Anr. …Respondents

WITH

CIVIL APPEAL NO. 5989 OF 2006

Transmission Corporation of A.P. Ltd. & Ors.    …Appellants

Versus

South Indian Sugar Mills Association & Anr. …Respondents

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WITH

CIVIL APPEAL NO. 5991 OF 2006

Transmission Corporation of A.P. Ltd.    …Appellants

Versus

M/s. Kaktiya Alloys (P) Ltd. & Ors. …Respondents

WITH

CIVIL APPEAL NO. 4106 OF 2006

Transmission Corporation of A.P. Ltd.    …Appellant

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Versus

Chodavaram Coop Sugar Ltd. & Ors. …Respondents

JUDGMENT

Swatanter Kumar, J.

1. Andhra Pradesh Electricity Regulatory Commission  (for  short  

‘Regulatory  Commission’)  was  created  in  furtherance  to  the  

provisions  of  the  Andhra  Pradesh  Electricity  Reform  Act,  1998  

(hereinafter  referred to  as the ‘Reform Act,  1998’)  enacted  by the  

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State legislature which received the assent of the President on 21st  

December,  1998  and  became  effective  w.e.f.  1st February,  1999.  

The Commission initiated suo motu proceedings for determination of  

tariff applicable to the Non-Conventional Energy generation projects  

of  Andhra  Pradesh,  which was to  take  effect  from 1st April,  2004  

onwards.   After  hearing  the  Non-Conventional  Power  Project  

Developers, the Non-Conventional Energy Development Corporation  

of  Andhra  Pradesh  Ltd.  and  Transmission  Corporation  of  Andhra  

Pradesh Ltd. (for short referred to as ‘NEDCAP’ and ‘APTRANSCO’  

respectively),  the  Regulatory  Commission,  vide  its  detailed  order  

dated 20th March, 2004, arrived at certain conclusions and fixed the  

energy  purchase  rates  at  base  unit  price  of  Rs.  2.25  as  on  1st  

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April,1994 and the escalation index of  5% p.a.,  but  the escalation  

would be simple and not  to be compounded every year.  In other  

words, the base price as on 1st April, 2004 will be Rs.3.37 per kwh.  

As these projects have no variable expenses and negligible increase  

in maintenance cost, the tariff will be frozen for a period of five year,  

which  however,  is  to  be  reviewed  thereafter.   The  Regulatory  

Commission also issued certain instructions to restrict and regulate  

various  operations  and  other  aspects.   It  restricted  the  sale,  

procurement and distribution of electricity by the Developers to any  

other  party except APTRANSCO. After  passing of  the order dated  

20th March,  2004  an  application  for  review  was  filed  by  the  

Developers  before  the  Regulatory  Commission.   The  order  was  

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clarified to some extent on this review application vide order dated 7th  

July, 2004.  Aggrieved from both these orders the Developers filed  

independent  appeals  under  Section  111(1)  of  the  Electricity  Act,  

2003  collectively  against  the  order  dated  20th March,  2004  as  

modified by order dated 7th July, 2004.  These appeals came up for  

hearing  before  the  Appellate  Tribunal  for  Electricity  (for  short  the  

‘Tribunal’) which decided all these appeals by a common order dated  

2nd June, 2006.  The Tribunal granted certain relief to the appellants  

before it,  who are the respondents in the present appeals,  holding  

that there was some element of duress in execution of the purchase  

price agreements.  The Power Purchase Agreement (for short ‘PPA’)  

was a statutory document and the Regulatory Commission had no  

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authority to interfere with the same.  It could not even be altered by  

the  Regulatory  Commission.   One  of  the  most  important  finding  

recorded by the Tribunal was that the Regulatory Commission has  

neither the power nor jurisdiction to compel the Developers to sell the  

power generated by them to APTRANSCO and/or DISCOM.  Feeling  

seriously aggrieved from the order of the Tribunal the Transmission  

Corporation  of  Andhra  Pradesh  Ltd.  as  well  as  Eastern  Power  

Distribution  Company  of  Andhra  Pradesh   Ltd.  have come up in  

appeal  before  this  Court  under  Section  125 of  the  Electricity  Act,  

2003.  Though the controversy, in the present case, appears to be a  

narrow  one  but  on  examination  it  is  clear  that  there  are  various  

ancillary questions, which need to be decided by the Court, prior to  

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answering  the  main  controversy  relating  to  the  jurisdiction  and  

fixation of tariff  by the Regulatory Commission. Arguments at great  

length were addressed by different learned counsel appearing for the  

parties.   Before  we notice  the  facts  in  detail  or  even refer  to  the  

contentions  raised,  it  will  be  appropriate  to  refer  to  the  issues  

involved  in  the  case  as  the  entire  matter  revolves  around  these  

questions  and answers thereto  and the  relief  granted.   For  better  

understanding  of  the  same,  let  us  refer  to  these  questions  and  

answers.   The comparative table of  the points  at  issue,  that  were  

raised, and the answers thereto are as under:

A.   Whether  a  Regulatory  Commission  has  the  power,  authority and jurisdiction either  

On  the  point  ‘A’,  we  hold  that  the  Regulatory  Commission  has  neither  the  power nor the authority nor jurisdiction to  

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under the Electricity Act, 2003  or  under  the  A  Electricity  Reform  Act,  1998  to  compel  the  Developers  to  sell  the  power  generated  by  them  to  the  State  Transmission  Utility  or Distribution Company?  

compel the Developers to sell the power  generated by them TO APTRANSCO or  DISCOMS.

B.  Whether  the  A.P.  Regulatory Commission having  approved  and  regulated  the  purchase  price  of  power  in  

terms  of   arrangement  and  PPA  entered  between  APTRANSCO and Developers  in terms of Sec. 21 (4)(B) and  11  (1)(e)  of  A.P.  Reform  Act  read with Sec. 86(1)(b) of 2003  Act  could  re-fix  the regulatory  purchase price by resorting to  tariff fixation under Section 62;  64 read with  Sec.  86(1)(a)  of  2003 Act?

On  the  point  ‘B’.  we  hold  that  the  Regulatory Commission having approved  the regulated the purchase price agreed  to  between  the  Developer  and  the  

TRANSCO in terms of Section 21 (4)(b)  and   11  (1)(e)  of  the  Andhra  Pradesh  Electricity  Reform Act,   1998  read  with  Section 86 (1)(b) of 2003 Act cannot re- fix  the  regulatory  purchase  price  by  resorting  to  tariff  fixation  under  Section  62; 64 read with Section 86(1)(a) of 2003  Act, as Section 86(1)(b) being  a special  provision  excludes  the  applicability  of  Section  86(1)(a)  of  the  2003  Act  to  private Generators.

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C.  Whether  the  A.P.  Regulatory  Commission  has  the power or authority to alter  the policy directions issued by  the  State  Government  with  respect  to  NCE  Developers?  Whether  the  Commission  could  claim  executive  power  with  respect  to  NCE  Developers  and  fixation  of  price  for  power  generated  by  

NCE  Developers  and  sold  to  APTRANSCO/DISCOM?

On the point ‘C’ and ‘F’, we hold that the  Andhra Pradesh Regulatory Commission  has  no  power  or  authority  to  alter  the  policy  direction  issued  by  the  State  Government  and  the  said  Commission  has  no  executive  power  nor  a  plenary  power as claimed by it.  

D.  Whether  the  plea  of  estoppel  advanced  by  Developers  is  sustainable  on  facts and law?

The  points  ‘D’  &  ‘E’  are  answered  in  favour  of  the  appellants  and  they  are  substantiated by the appellants.   

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E.  Whether  the  plea  of  legitimate  expectation  advanced  by  Developers  is  sustainable?

The  points  ‘D’  &  ‘E’  are  answered  in  favour  of  the  appellants  and  they  are  substantiated by the appellants

F. Whether the A.P. Electricity  Regulatory  Commission  is  possessed  of  Executive  Powers  to  issue  policy  and  executive directions in respect  of  NCE  Developers  in  the  State?

On the point ‘C’ and ‘F’, we hold that the  Andhra Pradesh Regulatory Commission  has  no  power  or  authority  to  alter  the  policy  direction  issued  by  the  State  Government  and  the  said  Commission  has  no  executive  power  nor  a  plenary  power as claimed by it.  

G.  Is  not  the  Commission  bound  by  directions  already  issued by the State in respect  of NCE Developers as well as  incentives  directed  by  the  given to encourage them?

On the point ‘G’,  we hold that the Andhra  Pradesh Electricity Regulatory  Commission is bound by policy directions  already issued by the State Government  so long as they are not modified or  altered.

H.  Whether  Regulatory  Commission  could  alter  or  change  the  PPAs  entered  between the  NCE Developers  and  Electricity  

On  the  point  ‘H’,  we  hold  that  the  Regulatory Commission has no authority  to  alter  or  change  the  PPAs  entered  between  the  NCE  Developers  and  Electricity Board/ APTRANSCO

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Board/APTRANSCO? I.  Whether  the  procurement  arrangement / PPA entered is  a statutory contract  and if  so,  whether  it  could  be interfered  by the Commission?

On  the  point  ‘I’,  we  hold  that  the  procurement  arrangement/PPA  is  statutory  and  the  Commission  has  no  authority to interfere with the same.

J. Whether the Commission is  just a regulator to approve the  PPA  entered  or  whether  it  could  determine  tariff  with  respect to NCE Developers?  

On  the  point  ‘J’,  we  hold  that  the  Commission  is  just  a  regulator  or  approve  the  PPA  entered  between  the  appellant  generator  and  the  APTRANSCO  by  examining  as  to  

whether the purchase is economical and  it is in terms of State Policy.

K.   Having approved PPA by  exercise of Regulatory Power,  is  it  open  to  commission  to  undertake  determination  of  tariff  in  respect  of  private  generation  by  NCE  Developers?

In the result on the ‘K’, we hold that the  appeals  preferred  by  the  NCE  Developers-Appellants  in  appeal  Nos.  1,2,5,6,7,8,9,10,12,15,16,17,18,19,20,21, 22,34,46,47,52,58, 67 & 80 of 2005 are  allowed and  the  impugned  proceedings  of  the  Regulatory  Commission  are  set  aside and there will be a direction to the  

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APTRANSCO,  the  Transmission  Corporation  of  AP,  the  Central  Power  Distributing  Company  of  AP  Ltd.,  the  Southern Power Distributing Company of  AP Ltd., the Northern Power Distributing  Company  of  AP  Ltd.  and  the  Eastern  Power  Distributing  Company  Limited  of  AP Ltd. to continue the Power Purchase  and at the same rate at which the power  generated  by NCE Developers  supplied  to them are being paid before passing of  

the  impugned  order  of  the  Commission  dated 20.03.2004 and 07.07.2004 made  in  R.P.  No.84/2003  and  O.P.  No.1075/2000  with  all  differences  and  arrears thereof, up to date and continue  to pay at the same rate, until a new PPA  is entered by agreement between them in  terms  of  State  Government  Policy  direction,  that  may  be  made  hereafter  and  approved  by  the  Regulatory  Commission.   This  Judgment  shall  be  

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given  effect  from  the  date  of  communication.   For  payment  of  tariff  difference  and arrears,  the  respondents  shall have six weeks from the date of this  Judgment, failing which the respondents  shall be liable to pay interest at 9% per  annum  with  effect  from  the  month  on  which the difference in tariff rate remains  to be paid ant till date of payment.

L. To what relief, if any? Consequently, the Appeal Nos. 46,48,49  and  50  of  2005  preferred  by  the  AP  

Transmission  Corporation  and  the  four  Discoms  will  stand  dismissed  as  there  are no merits in them. The parties shall  bear the respective cost throughout.

2. The above conclusions arrived at by the Tribunal on the factual  

matrix that the Government of Andhra Pradesh on 18th January, 1997  

by  GO Ms.  No.  93,  with  the  object  of  encouraging  generation  of  

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electricity  from  renewable  sources  of  energy,  allowed  uniform  

charges to all such projects.  After issuance of the above GO Ms. 93  

certain  ambiguities  were  noticed  by  the  concerned  parties.   This  

resulted in issuance of GO Ms. No. 112 dated 22nd December, 1998  

and vide this GO clarifications were issued to the earlier Government  

order  and  it  clearly  provided  for  uniform  implementation  of  the  

proposed  scheme  to  all  non-conventional  energy  

developers/generators  of  power.   The  Andhra  Pradesh  Electricity  

Regulatory Commission was constituted under the said Reform Act,  

1998 vide notification dated 3rd April, 1999 and the same Commission  

performing the duties and functions under the above Act continued to  

be a Commission under and within the meaning of  Electricity Act,  

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2003  as  well.   This  was  done  by  virtue  of  Section  185  of  the  

Electricity Act, 2003.  State Government of Andhra Pradesh notified  

the  Transmission  Corporation  of  Andhra  Pradesh  to  be  the  State  

Transmission utility.   We may also notice here that the  Electricity  

Regulatory Commissions Act, 1998 also contemplated under Section  

3,  constitution  of  a  Central  Electricity  Regulatory  Commission  to  

exercise the powers conferred and functions assigned to it under the  

Act.   In terms of Section 17 of this Act the State Government was  

also to notify in the official gazette and establish, for the purposes of  

this  Act  a  Commission  for  the  State  to  be  known  as  the  State  

Electricity Regulatory Commission.  In terms of Section 22 of this Act  

the functions of the State Commission were defined, which included  

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determination of tariff for electricity, wholesale, bulk, grid or retail, as  

the case may be.  Under Section 11 of the Reform Act, 1998 it has  

been  spelt  out  as  to  what  are  the  functions  of  the  Regulatory  

Commission,  inter  alia,  it  provides to  aid  and advise to  the  State  

Government,  in  matters  concerning  electricity  generation,  

transmission, distribution and supply in the State, to issue licences in  

accordance  with  the  provisions  of  this  Act  and  determine  the  

conditions to be included in the licences, to regulate the purchase,  

distribution, supply and utilization of electricity, the quality of service,  

the tariff and charges payable keeping in view both the interest of the  

consumer  as  well  as  the  consideration  that  the  supply  and  

distribution  cannot  be  maintained  unless  the  charges  for  the  

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electricity  supplied  are  adequately  levied  and  duly  collected,  to  

require  licensees  to  formulate  prospective  plans  and  schemes  in  

cooperation  with  others  for  the  promotion  of  generation,  

transmission,  distribution  and  supply of  electricity.   Besides  these  

powers, which have been noticed by us, inter alia, the residue clause  

has been worded very widely to permit the Regulatory Commission to  

undertake all  incidental  or ancillary things.   Under Section 15,  the  

Regulatory Commission is vested with the power to issue licences  

and  to  enter  into  agreements  on  specified  terms  and  also  to  

determine the charges and establish tariff in terms of clause (5) of  

Section 15 of the Reform Act, 1998. It needs to be noticed that the  

State of Andhra Pradesh was vested with the powers and infact the  

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duty to constitute the Regulatory Commission in terms of Section 11  

afore noticed.

3. The  Regulatory  Commission  was  constituted  as  per  the  

provisions of Reform Act, 1998 vide notification dated 3rd April, 1999  

and  it  was  to  perform  all  regulatory  functions  pertaining  to  the  

electricity industry in the State of Andhra Pradesh.  It was commonly  

agreed  before  us  during  the  course  of  argument  that  it  is  the  

Electricity Regulatory Commission for the State of Andhra Pradesh  

for all intent and purposes under the Reform Act, 1998 as well as the  

Electricity Act, 2003.  We must notice, at this stage itself,  that the  

Tribunal  has  entertained  the  doubt  that  since  no  independent  

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notification  was  issued  under  Section  17  of  Electricity  Regulatory  

Commission Act,  1998, therefore,  it  could not exercise the powers  

vested in the Regulatory Commission under that Act.  This may not  

be  the  correct  position  in  law.   The  Regulatory  Commission  was  

constituted  under  the  Reform  Act,  1998  and  an  appropriate  

notification  in  that  behalf  was  issued.   The  Electricity  Regulatory  

Commission Act,  1998 stood repealed by the Electricity Act,  2003.  

The Electricity  Act,  2003 specifically recognized  and accepted  the  

Commissions  constituted  under  the  enactments  specified  in  the  

schedule to the Act as appropriate Commission. In entry 3 of the said  

schedule, Reform Act, 1998 has been specifically noticed.  In other  

words, the Regulatory Commission constituted under the Reform Act,  

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1998 became the appropriate commission under the Electricity Act,  

2003 as well.

4. In exercise of its powers, the Regulatory Commission claims to  

have  issued  licences  to  Transmission  Corporation  as  well  as  

DISCOM for bulk and retail supply of electricity w.e.f. 1st April, 2001.  

Vide order dated 20th June, 2001 made in OP No. 1075 of 2000, the  

Regulatory  Commission  directed  generators  of  Non-Conventional  

Energy  to  supply  power  exclusively  to  APTRANSCO.   The  Non-

Conventional  Energy  Developers  were  not  permitted  to  sell  the  

energy generated  by them to  3rd parties.   By the  same order  the  

Regulatory Commission also approved the rate which was prevailing  

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earlier for such supply at Rs. 2.25 per unit with 5% escalation per  

annum from 1994-95 being the base year.  After coming into force of  

the Electricity  Act,  2003,  Regulatory Commission  issued notice on  

23rd October,  2003 inviting objections from various Developers and  

Generators  to  the  proposals  of  APTRANSCO  and   NEDCAP  in  

regard  to  fixation  of  price  to  be  paid  by  APTRANSCO   for  the  

quantum  of  electricity   purchased  from  non-conventional  energy  

projects w.e.f. 1st April, 2004.  The objections, if any, were to be filed  

on or before 5th November, 2003.  NEDCAP and DISCOM were to  

submit proposals for review of incentives.  The proposal had been  

received  for  review  by  the  Regulatory  Commission  from  

APTRANSCO.  Within the extended time the Developers, individually  

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as well as acting through their Association, filed various objections in  

response to the notice dated 23rd October, 2003.  All the parties were  

granted hearing by the Regulatory Commission which, then, passed  

the  order  dated  20th March,  2004,  reducing  the  price  payable  by  

APTRANSCO to Non-Conventional Energy Developers towards the  

supply of electricity.  Some of the Developers moved to the Andhra  

Pradesh  High Court  by filing  a  Writ  Petition  No.  7222 of  2004 in  

which  interim  order  dated  15th April,  2004  came  to  be  passed  

directing APTRANSCO to continue to pay to NCE Developers for the  

power that may be supplied by them as per the earlier rates prevalent  

on 1st April, 2004.  By order dated 27th April, 2004, the High Court  

disposed of the batch of the Writ Petitions while issuing the direction  

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to the Developers to approach the Regulatory Commission and seek  

review  of  its  order  dated  20th March,  2004.   The  Regulatory  

Commission  was also  directed  to  take  up the  review petition  and  

dispose of the same within 8 weeks.  Till then, the interim order dated  

15th April, 2004 was to remain in force.  This resulted in filing of the  

Review  Petitions  before  the  Regulatory  Commission.   In  the  

meanwhile the Govt. of Andhra Pradesh ordered that APTRANSCO  

shall cease to engage in trading relating functions and that the PPAs  

entered with the Developers  shall  vest  in DISCOM(s)   w.e.f.   10th  

June, 2004 in terms of Section 39 read with Section 172(b) of the  

Electricity Act, 2003.  The Review Petitions filed by the Developers  

before the Regulatory Commission came to be dismissed by different  

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orders passed on 5th July, 2004 and 10th July, 2004 respectively.  The  

Review Petition filed by APTRANSCO also came to be dismissed on  

11th July, 2004. This resulted in approaching the High Court again, by  

nine of the developers, filing Writ Petition No. 16621 of 2004.  The  

High Court, vide its order dated 16th September, 2004, permitted the  

implementation  of  the  revised  tariff  by  APTRANSCO.  It  further  

directed that 50% of the differential amount between the old and the  

revised tariff shall also be paid for the actual power supplied.  By GO  

58 dated 7th June,  2005, an approval scheme came to be framed  

under the Reform Act, 1998 to transfer and distribute the assets and  

contracts  of  bulk  supply and trading  business  of  APTRANSCO to  

DISCOM which was in furtherance to the earlier decision of the State  

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of  Andhra  Pradesh.   Ultimately  these  Writ  Petitions  came  to  be  

disposed of with the direction that the Developers shall approach the  

Tribunal  and  the  interim  order  shall  continue  to  be  in  force  for  a  

period of 8 weeks from 15th June, 2005 or till  the Tribunal passes  

order on the interim application, whichever is earlier.  Same interim  

order was passed by the Tribunal during the pendency of the appeal  

which, were filed before it.  

5. As is obvious from the above narrated facts and again, it is not  

in dispute that  the Regulatory Commission passed an order dated  

20th June,  2001 which,  in fact,  attained finality and its correctness  

was  never  been  questioned  by  any  of  the  parties  including  the  

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present appellants.  Thus, the order dated 20th June, 2001 is of some  

significance  and  certainly  of  some  definite  relevancy.  The  

proceedings were initiated  suo motu by the Regulatory Commission  

against all the Developers of Non-Conventional Energy including mini  

hydro  projects.   The Regulatory  Commission  noticed,  in  its  order  

dated 20th June, 2001 that Govt. of India issued guidelines regarding  

promotional  and  fiscal  incentives  to  be  given  by  the  State  

Governments  for  power  generation   through  Non-Conventional  

Energy sources.  The Govt. of Andhra Pradesh issued order No. 19  

dated 16th March, 1996 under which it accorded certain incentives in  

respect of the Developers with whom NEDCAP had entered into the  

memorandum of understanding.   A review of these incentives was  

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taken after which GO Ms. 93 dated 18th November, 1997 was issued,  

as already noticed and it was decided to provide uniformity to all the  

projects based on renewable sources of  energy like Waste,  Wind,  

Bio-mass, Co-generation, Municipal Waste and Mini Hydro projects.

6. The  Regulatory  Commission  had  passed  an  order  dated  6th  

March, 2000 giving certain directions including that the Developers  

could  sell  the  power  generated  by  them  to  third  party  upto  17th  

November,  2000.   The rates  were  indicated,  as  we have already  

noticed, and that there would be reviewed with regard to purchase  

price with reference to each Developer on completion of  10 years  

from the date of the commission of the project. After noticing various  

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objections that had been raised by the Developers it was stated that  

the Regulatory Commission was not attempting to stop any incentive  

while  referring  to  the  statistics  and  the  market  conditions.  It  was  

specifically  noticed  that  permitting  Non-Conventional  Energy  

Developers  to  make  third  party  sales  would not,  at  all,  be  in  the  

interest of organized growth of electricity industry and it would create  

discrimination between the industrial consumer drawing power from  

Non-Conventional Energy Developers and the industrial  consumers  

drawing power from APTRANSCO and these two would have to pay  

two  different  rates.   It  also  noticed  that  there  will  be  undue  

enrichment  of  the Developers  as they were permitted  to  establish  

their generation plants with definite benefits which were carried out  

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for  years together.   While holding that the Regulatory Commission  

had  jurisdiction,  it  also  noticed  that  the  rate  approved  by  the  

Regulatory  Commission  on  the  basis  of  guidelines  issued  by  the  

Ministry of Non-Conventional Energy Sources are much higher than  

the rate permitted  by the State Government  and in comparison to  

other  States  they  were  favourable  to  the  NCE  developers.   This  

reasoning   persuaded  the  Regulatory  Commission  to  pass  the  

following directions:

“29.  The existing incentives under G.O. Ms. No.  93,  dated  18.11.1997,  which are continued  under  the orders of the Commission from time to time till  24.06.2001 under our letter No. 2473, Dated 24-04- 2001  are  extended  for  the  time  being  till  24-07- 2001.  The temporary extension has been given to  enable  the  developers  to  finalise  

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agreements’/arrangements  relating  to  supply  of  power to APTRANSCO prior to 24-07-2001).  With  effect  from  the  billing  month  of  August  2001,  all  generators of non-conventional energy shall supply  power  to  APTRANSCO only  as  per  the  following  terms:  

(i) Power generated by non-conventional energy  developers  is  not  permitted  for  sale  to  third  parties.

(i) Developers of  non-conventional  energy shall  supply  power  generated  to  APTRANSCO/DISCOMS of A.P. only.

(i) Price  applicable  for  the  purchase  by  the  supply licensee should be Rs.  2.25 per unit  with 5% escalation per annum with 1994-95  as the base year.

APTRANSCO is simultaneously directed to arrange  payment  for  the  supply  of  power  purchased  from  

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developers of non-conventional energy by opening  a Letter of Credit in favour of the suppliers of power.   30. A suo motu review of  the incentives to take  effect from 1st April, 2004, will be undertaken by the  Commission  after  discussions  with  all  the  concerned parties.  There will also be a review of  the purchase price with specific reference to each  developer on completion of 10 years from the date  of commissioning of the project (by which time the  loans  from  financial  institutions  would  have  been  

repaid)  when the purchase price will  be reworked  on the basis of return on enquity.  O&M expenses  and the variable cost.

31. However, if any developer wishes to raise any  specific issue with reference to this order, he will be  entitled to apply to the Commission in the manner  provided in the regulations.”

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7. After passing of this order by the Regulatory Commission the  

parties executed PPAs.  These agreements were signed on the lines  

of  the directives given in the order of  Regulatory Commission.   In  

fact, it was stated that the agreements were required to be and were  

actually approved by the Regulatory Commission. In terms of Clause  

5  of  the  PPA  these  agreements  were  enforceable  subject  to  

obtaining consent of the Regulatory Commission as per Section 21 of  

the Reform Act, 1998.  Obviously, the rates and conditions specified  

in the earlier proceedings of 11th November,1999, 1st April, 2000, 27th  

January,  2001 and  13th July,  2001 were accepted  by the  parties.  

Some of the clauses of the PPA, which have also been heavily relied  

upon by the learned counsel for the parties, read as under:

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“ARTICLE 2 PURCHASE OF DELIVERED ENERGY AND TARIFF

2 All the Delivered Energy at the interconnection point for  sale  to  APTRANSCO will  be purchased  at  the  tariff provided for in Article 2.2 from and after the  date  of  Commercial  Operation  of  the  Project.  

Title  to Delivered Energy purchased shall  pass  from the Company to  the  APTRANSCO at  the  Interconnection Point.

3 The  Company  shall  be  paid  the  tariff  for  the  energy  delivered  at  the  interconnection  point  for  sale  to  APTRANSCO at Rs. 2.25 paise per unit with escalation at  5%  per  annum with  1994-95  as  base  year  and  to  be  revised  on  1st April  of  every year  upto  the  year  2003- 2004.  Beyond the year 2003-2004, the purchase price by  APTRANSCO  will  be  decided  by  Andhra  Pradesh  Electricity Regulatory Commission.  There will be further  

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review of purchase price on completion of ten years from  the  date  of  commissioning  of  the  project,  when  the  purchase price will be reworked on the basis of Return on  Equity, O & M expenses and the Variable Cost.”

8. Besides  the  above clauses  it  also  provided other  terms and  

conditions under different articles, which are not necessary for us to  

be  noticed  at  this  stage.  It  required  to  be  noticed  with  some  

significance  that  no  disputes  of  any  kind  were  raised  by  the  

Developers till and after passing of the order dated 20th March, 2004.  

The  order  of  20th June,  2001  read  in  conjunction  with  the  PPAs  

executed by the parties controlled the entire field and all the persons  

including the Regulatory Commission as well as the State therein.  

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9. This period of nearly three years, thus, was free of grievances  

and  objections  and  the  order  of  2001  appears  to  have  been  

implemented  willingly by the  parties.   There was execution  of  the  

PPAs completely  bringing  the  matter  between the  parties  into  the  

realm of contract.  Thereafter, the Regulatory Commission in terms of  

its  2001 order appears to have initiated  suo motu  proceedings for  

determination of tariff for non-conventional energy projects of Andhra  

Pradesh  with  effect  from  1st April,  2004.   The  Regulatory  

Commission, in its order dated 20th March, 2004 has also noticed the  

background facts of the case and the determination of rates earlier.  

It  had given notice to all the developers and other shareholders to  

submit their views and objections on the above issues.  After hearing  

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the parties, the Regulatory Commission considered the proposal for  

tariff.  The proposal submitted by APTRANSCO and NEDCAP were  

as under :  

“APTRANSCO’s Tariff Proposals

Particulars Unit Tariff (Levelised Tariff  over the life of the project)

Year-on-year escalation

Existing  

Plants Rs/kWhr.

New Plants

Rs/kWhr.

Existing New

Mini Hydel 2.42 2.31 --- --- Bagasse 2.23 2.25 2% 2% Biomass 2.27 2.27 2% 2% Waste to  Energy

Nil 2.66 --- 1%

Wind 2.52 2.55 --- ---

NEDCAP Tariff proposals:

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Bagasse Rs. 2.62 – Ist year Rs. 2.48 – 10th year

Biomass Rs. 3.27 – Ist year Rs. 3.77 – 10th year

Mini Hydel Rs. 2.96 – Ist year Rs. 2.26 – 10th year

Wind Farm Rs. 4.54 – Ist year Rs. 3.19 – 10th year

Waste to Energy Rs. 2.99 – Ist year Rs. 3.19 – 10th year

10. Objections  to  the  above  proposals  were  also  received.  

Interestingly  and  rightly  so,  the  Regulatory  Commission  before  

analyzing the proposal and objections, noticed:

“20….as  mentioned  herein  above,  the  Commission,  in  this  order  is  not  examining  any issues concerning the direction contained  in  the  order  dated  20.6.2001  that  the  NCE  

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Developers  shall  not  sell  electricity  to  third  parties and they are required to sell electricity  only to APTRANSCO.   The Commission, in  this  order,  is  dealing  with  only  those  NCE  Developers  who  had  accepted  the  order  dated 20.6.2001 and voluntarily agreed to sell  electricity to APTRANSCO on the terms and  conditions  contained  in  the  order  dated  20.6.2001”

11. While  the  Regulatory  Commission  undertook  the  review  of  

prices in relation to sale of electricity by Non-Conventional  Energy  

developers, it specifically referred to order in O.P. No. 1075 of 2000,  

which, in turn, provided for review of sale price and incentives given  

earlier to the said developers with effect from 1st April, 2004.  It also  

noticed  that  the  PPAs  signed  by  the  APTRANSCO  and  NCE  

Developers  include  provisions  for  such  review  by  the  Regulatory  

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Commission with effect from 1st April,  2004.   It  took the view that  

review of the price at which APTRANSCO shall purchase power from  

the  NCE  developers  is  within  the  jurisdiction  of  the  Regulatory  

Commission under Section 21(4) of the Reform Act, 1998 and also  

under Section 86(1) of the Electricity Act, 2003.  Referring to Section  

61  of  the  Electricity  Act,  2003  which  cast  obligation  upon  the  

Regulatory  Commission  to  frame  tariff  regulations  specifying  the  

terms and conditions for  determination  of  tariff,  in  para 21 of  that  

order, the Regulatory Commission framed the following issues:  

“Issues for consideration on merits:

The  Commission  has  considered  inter  alia,  the  following issues:  

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(i) Whether the tariffs and incentives should be  uniform for all the categories of NCE projects  as provided earlier in MNES guidelines, GoAP  orders  and  APERC’s  order  OP.  No.  1075/2000 dated 20.6.2001 or should they be  different  for  different  categories  of  NCE  projects.

(i) Whether the tariff should be a single part tariff  or a two part tariff.

(i) Whether the tariff should be project specific or  uniform for all project falling in a category.

(i) Whether there should be a cap on tariff when  a  project  exceeds  the  expected  minimum  performance.   

(i) Social and environmental considerations.

(i) Control period.”

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12. The Regulatory Commission decided tariff fixation in relation to  

Bagasse  based  co-generation  plants,  Bio-mass  power  generation  

and Mini hydel projects separately.  The specific issue raised by the  

objectors was that the benchmarking of capital cost should be based  

on market trends, confirmed through competitive bidding from time to  

time.   Though APTRANSCO accepted this  in  principle,  but  stated  

that  they  expect  a  detailed  procedure  from  the  Regulatory  

Commission for an effective competent bidding. The tariff basis was  

questioned as well as it  was submitted that tariff  beyond threshold  

limit should be limited to the variable cost and incentives only and not  

the full tariff.  This was opposed by APTRANSCO which preferred a  

single  time  tariff  in  entire  energy  purchase.   While  taking  into  

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consideration the applicability of depreciation and its extent the tariff  

was  fixed  and  the  Regulatory  Commission  drew  the  following  

conclusion:

“81.  The  tariffs  arrived  at  along  with  escalation  under  each  category  will  be  applicable  as  detailed  in  the  respective  paragraphs  under  each  category.   The  aforementioned  tariffs  are,  however,  also  

subject to the following:  

“i. In regard to tariff for Bagasse based co- generation  projects,  where  the  Plant  Load Factor during a settlement period  exceeds  55%  (the  level  at  which  the  fixed cost is expected to be recovered),  only  incentive  of  21.5  paise/unit  and  variable cost  as  indicated  in  para (47)  above  shall  be  paid  for  every  unit  delivered in excess of the 55% PLF.

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ii. As regards to tariff  for  Biomass based  power  projects,  where  the  Plant  Load  Factor  during  a  settlement  period  exceeds  80%  (the  level  at  which  the  fixed cost is expected to be recovered),  only  incentive  of  21.5  paise/unit  and  variable cost  as  indicated  in  para (63)  above  shall  be  paid  for  every  unit  delivered in excess of 80% PLF.

ii. The tariff  for  mini-hydel power projects  is exclusive of Royalty.

ii. In the case of tariff for mini-hydel power  projects,  where  the  PLF  during  settlement period exceeds 35%, only an  incentive of 21.5 paise/kwh shall be paid  for  every  unit  delivered  in  excess  of  35%.

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ii. The  tariffs  authorized  above  will  be  applicable  w.e.f.  1.4.2004  to  all  NCE  power  plants  of  respective  categories  for sale to APTRANSCO.

ii. The  above  tariff  structure  is  valid  for  control  period  of  five  years  with  effect  from  1.4.2004.   Thereafter,  the  Commission  will  review the prices  and  incentives  after  consultation  with  the  Developers and licensees.

ii. A  further  review  of  the  individual  projects  will  be  undertaken  on  completion of 10 years from the date of  commissioning of the project,  by which  time the loan is expected to have been  substantially  repaid,  and  the  purchase  price  will  be  based  on  O  &  M  expenditure,  return  on  equity,  variable  cost and residual depreciation, if any.

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ii. For  those  developers’  having  captive  consumption who supply excess energy  to  APTRANSCO  after  meeting  their  internal  consumption,  the  current  practice  of  meter  reading  at  the  interconnection  point  and  grossing  up  for  auxiliary  consumption  in  order  to  arrive at PLF will be misleading as it will  not  take  into  consideration  the  captive  consumption.   The incentive  payments  begin after  threshold PLF.  In order to  

ascertain the PLF levels, APTRANSCO  should  make  arrangements  for  authenticated  meter  reading  at  the  generator terminals so that the two-tier  tariff is properly implemented.

ii. Developers  will  be  entitled  to  dispatch  100% of  the available capacity without  reference  to  Merit  Order  Dispatch  subject,  however,  to  any  system  constrains.”  

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13. After  arriving  at  this  conclusion  the  Regulatory  Commission  

also specifically clarified that as and when, however, trading function  

of APTRANSCO is segregated and vested in new entity pursuant to  

the Electricity Act, 2003, the terms and conditions contained therein  

shall  be  binding  on  the  new  entity  in  the  same  manner  as  was  

applicable to APTRANSCO.

14. As is clear from the order itself that it dealt with, primarily, the  

question of  refund/fixation of  tariff  in relation to various generation  

projects.  It  decided no other  matter  and even these findings were  

subsequently questioned by the Developers before the High Court  

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and in furtherance  to the order  of  the High Court  dated 15th July,  

2004, Review Petitions were filed, which finally resulted in filing of the  

appeals before the Tribunal.

15. We may notice here that vide notification dated 28th May, 2004,  

the  State  Government  ordered  that  APTRANSCO  shall  cease  to  

engage in trading relating functions and that the PPAs entered with  

the Developers shall vest in DISCOM  w.e.f. 10th June, 2004 in terms  

of Section 39 read with Section 172(b) of the Electricity Act, 2003.  

On 9th June, 2004, the Central Government also authorized the State  

Transmission  Utility  to  engage  in  bulk  purchase  and  sell  it  to  

DISCOM for a period of one year from 10th June, 2004.  With this  

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background,  the  appeals  which  were  filed  before  the  Appellate  

Tribunal came up for hearing and some appeals were also filed by  

DISCOM with APTRANSCO as a party.  Appeals  from both sides  

came  up,  heard  and  decided  by  the  order  dated  2nd June,  2006  

impugned in the present case.

16. Now with this factual background, we shall proceed to examine  

the issues of law raised in the present appeals before this Court.  As  

already  noticed,  in  paragraph  40  of  the  impugned  judgment,  the  

Tribunal had framed as many as 12 points for determination which  

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were answered by it in paragraph 114.  The points formulated by the  

Tribunal, in fact, can be categorized in the following principal heads:

(i) Matters relating to jurisdiction of the Commission for fixation  of tariff and sale of generated electricity to third party;

(i) Correctness of tariff fixation on merits of the case;

(ii) Is the principle of estoppel attracted in the present case, if  so, to what extent?

(i) Does the plea of duress need to be accepted as per settled  principles and with reference to the facts of the case?

(i) What is the effect of order dated 20.6.2001 having attained  finality  and  even  not  being  questioned  in  the  present  proceedings?

(i) What orders can be made by this Court to deal with these  appeals to do complete justice between the parties?

 

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           17. Fixation of tariff is, primarily, a function to be performed by the  

statutory  authority  in  furtherance  to  the  provisions  of  the  relevant  

laws.  We have already noticed that  fixation of tariff  is a statutory  

function as specified under the provisions of the Reform Act, 1998,  

Electricity Regulatory Commissions Act, 1998 and the Electricity Act,  

2003. These functions are required to be performed by the expert  

bodies to whom the job is assigned under the law.  For example,  

Section  62  of  the  Electricity  Act,  2003  requires  an  appropriate  

Commission to determine the tariff in accordance with the provisions  

of  the  Act.  The Regulatory Commission  has been constituted  and  

notified under the provisions of Section 3 read with Section 11 of the  

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Reform Act, 1998 which in terms of Section 11(1)(c)&(e) is expected  

to  fix  the  tariff  as  well  as  the  terms  of  licence.   There  are  three  

different legislations in course and the Regulatory Commission has  

been constituted under the Reform Act, 1998 which in turn would be  

the  Commission  as  contemplated  under  the  Electricity  Regulatory  

Commission Act, 1998 and the Electricity Act, 2003.   In terms of first  

proviso  to  Section  82(1)  of  the  Electricity  Act,  2003  the  State  

Electricity  Regulatory  Commission  established  by  the  State  

Government  under  Section  17  of  the  Electricity  Regulatory  

Commission Act, 1998 and the enactment specified in the schedule  

shall be the State Commission for the purposes of this Act.  Even in  

terms of Section 185(3) of the Electricity Act, 2003 the said authority  

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would be deemed to be an appropriate Commission for all purposes  

and intent as the Reform Act, 1998  has been specifically mentioned  

in entry 3 of the Schedule to the Electricity Act, 2003.  In other words,  

as  already noticed  the  Regulatory  Commission  constituted  by the  

said  notification  would  be  the  appropriate  Commission  under  all  

these Acts and is required to perform the functions as contemplated  

under Sections 11, 17 and 82 of the respective Acts.  The functions  

assigned  to  the  Regulatory  Commission  are  wide  enough  to  

specifically impose an obligation on the Regulatory Commission to  

determine the tariff.  The specialized performance of functions that  

are assigned to Regulatory Commission can hardly be assumed by  

any other authority and particularly, the Courts in exercise of their  

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judicial discretion.  The Tribunal constituted under the provisions of  

the Electricity Act, 2003, again being a specialized body, is expected  

to examine such issues, but this Court in exercise of its powers under  

Article 136 of the Constitution would not sit as an appellate authority  

over  the  formation  of  opinion  and  determination  of  tariff  by  the  

specialized bodies.  We would prefer to leave this question open to  

be considered by the appropriate authority at the appropriate stage.  

We do not consider it appropriate to go into the merit or de-merit of  

determination of tariff rates in the appeals.  Determination of tariff is a  

function  assigned  legislatively  to  a  competent  forum/authority.  

Whether  it  is  by  exercise  of  legislative  or  subordinate  legislative  

power or a policy decision, if the Act so requires, but it generally falls  

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in  the  domain  of  legislative  activity  and  the  Courts  refrain  from  

adverting into this arena.   

18. We have to further examine the legality of this issue in the light  

of  the findings that  we have recorded on the issues in relation to  

jurisdiction  of  the  Regulatory  Commission  to  determine/review the  

tariff.   The jurisdiction of  this Court  is  limited in this aspect.   This  

Court has consistently taken the view that it would not be proper for  

the Court to examine the fixation of tariff rates or its revision as these  

matters are policy matters outside the preview of judicial intervention.  

The only explanation for judicial intervention in tariff fixation/revision  

is where the person aggrieved can show that the tariff  fixation was  

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illegal, arbitrary or ultra virus the Act.  It would be termed as illegal if  

statutorily prescribed procedure is not followed or it  is so perverse  

and arbitrary that it hurts the judicial conscious of the Court making it  

necessary for the Court to intervene.  Even in these cases the scope  

of  jurisdiction  is  a  very  limited  one.   This  Court  in  the  case  of  

Association of Industrial Electricity Users v. State of Andhra Pradesh  

[(2002)  3  SCC 711],   while   dealing  with  the  provisions  of  tariff  

fixation in terms of the provisions of the Reform Act, 1998, observed  

that even where the Act did not envisage classification of consumers  

according to the purpose for which electricity is used, Sub-Section(9)  

of Section 26 of that Act does state that the tariff  rate relatable to  

classification  of  consumers  would  be  permissible,  of  course,  

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depending upon various factors stipulated in Section 26(7) of the Act.  

The Court finally held as under:

“11. We also agree with the High Court that  the judicial review in a matter with regard to  fixation  of  tariff  has  not  to  be as that  of  an  Appellate  Authority  in  exercise  of  its  jurisdiction  under  Article  226  of  the  Constitution. All that the High Court has to be  satisfied  with  is  that  the  Commission  has  

followed the  proper  procedure  and unless  it  can be demonstrated  that  its  decision is  on  the face of it arbitrary or illegal or contrary to  the Act,  the court  will  not  interfere.  Fixing a  tariff  and  providing  for  cross-subsidy  is  essentially a matter of policy and normally a  court  would  refrain  from  interfering  with  a  policy decision unless the power exercised is  arbitrary or ex facie bad in law.”

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19. Similarly,  in  the  case  of  West  Bengal  Electricity  Regulatory  

Commission   v.  CESC Ltd.  [(2002)  8  SCC 715],  this  Court  was  

concerned with determination of tariff by the State Commission, the  

applicability  of  principles  of  natural  justice  and  the  scope  of  

interference by the High Court in distinction to the power exercisable  

by the appellate authority.  Stating it to be a function in the nature of  

legislative power, the Court felt that the principles of natural justice  

were not attracted and the power of judicial review could hardly be  

invoked.  The Court held as under:

“39. Having considered the finding of the High  Court,  we  are  of  the  opinion  that  though  generally it is true that the price fixation is in  the nature of a legislative action and no rule of  natural justice is applicable (see Shri Sitaram  

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Sugar  Co.  Ltd. v.  Union of  India SCC, para  45),  the  said  principle  cannot  be  applied  where the statute itself has provided a right of  representation  to  the  party  concerned.  Therefore, it will be our endeavour to find out  whether, as contended by learned counsel for  the appellants, the statute has provided such  a right to the consumers or not.

xxx               xxx                xxx                xxx

44.  Having  held  on  merits  that  the  Regulations  are  not  arbitrary  and  are  in  conformity with the provisions of the Act, we  will  now  consider  whether  the  High  Court  could  have gone into  this  issue at  all  in  an  appeal filed by the respondent Company. First  of  all,  we  notice  that  the  High  Court  has  proceeded  to  declare  the  Regulations  contrary to the Act in a proceeding which was  initiated before it in its appellate power under  Section 27 of the Act. The appellate power of  the High Court in the instant case is derived  from the 1998 Act. The Regulations framed by  

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the  Commission  are  under  the  authority  of  subordinate  legislation  conferred  on  the  Commission  in  Section  58 of  the  1998 Act.  The Regulations so framed have been placed  before the West Bengal Legislature, therefore  they have become a part of the statute. That  being so, in our opinion the High Court sitting  as  an  appellate  court  under  the  1998  Act  could  not  have gone into  the  validity of  the  said  Regulations  in  exercise  of  its  appellate  power.”

20. In  view of  the  above  settled  position  of  law  we  are  of  the  

considered  opinion that  the present  case is  one where this  Court  

should examine determination of tariff  on merits and particularly, in  

view of the directions that we propose to pass finally in this case.

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21. The  issue  relating  to  jurisdiction,  again,  would  have  to  be  

divided  into  two  different  parts.  Firstly,  whether  the  Regulatory  

Commission could exercise the powers for determination and/or re-

fixing the price by resorting to tariff fixation powers under the Act and  

secondly,  with  regard  to  sale  of  generated  electricity  by  the  

Generators  to  parties  other  than  State  Transmission  Utility  or  

Distribution Company.  In regard to first part of this issue the Tribunal  

in  its  order,  while  answering  issue  B,  held  that  Regulatory  

Commission has no jurisdiction to re-fix the regulatory purchase price  

by resorting to tariff fixation methods specified under the provisions  

of  law.   Similarly,  it  also  answered  issue  A  in  the  negative  and  

against the Regulatory Commission.  The primary reason recorded  

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by  the  Tribunal  is  that  the  original  fixation  of  purchase  price  for  

energy  generated  by  NCE  Developers  is  in  terms  of  the  policy  

directions issued by the State and it was not within the jurisdiction  

and scope of the powers conferred upon the Regulatory Commission  

under the Reform Act, 1998.  It was considered by the Tribunal that  

policy decision of the State could not have been set at naught on the  

assumption that the Regulatory Commission is vested with executive  

powers.   Also that  Regulatory Commission  had proceeded on the  

basis  that  it  has  power  to  review  the  rate/incentives  given  to  

developers  or  it  has  power  to  issue  executive  directions.   The  

Tribunal  also  felt  that  PPAs  are  final  and  binding  and  there  is  

assumption of power on the part of the Regulatory Commission that  

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they have authority to fix tariff  with respect to power generators by  

taking recourse to provisions of Sections 62, 64 read with Section  

86(1) of  Electricity Act, 2003.

22. Before  we proceed  to  examine the  various provisions  under  

different Acts afore referred, let us once again refer, in precise form,  

the  necessary  facts.   From  the  record  it  appears  that  on  7th  

September, 1993 the Ministry of Non-Conventional Energy Sources,  

New Delhi had written a letter to the Chief Secretary of the different  

States informing them that under the new strategy  and action plan of  

the ministry special  emphasis is sought to be given to generation of  

grid  quality  power  from non-conventional  energy sources,  noticing  

that  the  average  cost  of  power  generation  from  non-conventional  

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energy sources compares quite favourably with new coal thermal/gas  

based projects and captive diesel generating sets.  While in future  

the costs of the former are expected to drop, costs of conventional  

electricity  generation  will  only increase.   Referring  to  the  fact  that  

Central  Government  has  introduced  several  fiscal  and  other  

promotional  incentives  to  attract  private  sector  participation  in  the  

generation  and  supply  of  energy  from  non-conventional  energy  

sources and consequently the States had also introduced measures  

such  as  wheeling and banking,  buy back,  third  party sale,  capital  

subsidies, industry status, sales tax exemption etc., it had also been  

noticed that they were to vary in operation from State to State.  In this  

background  the  Ministry  had  drawn  up  guidelines  which  was  

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enclosed to that letter and asked all States to work towards a uniform  

policy  pertaining  to  the  non-conventional  energy  sources.   A  

minimum buy back price of Rs. 2.25 per unit had been proposed and  

it  required  the  States  to  consider  that  these  guidelines  were  not  

exhaustive.  Other matters, including additional incentives, attractive  

packages  could  be  formulated  by  the  State  and  accordingly  the  

States were required to take further steps.  The very opening part of  

the guidelines dealt with the operative period and it was stated that  

“The  Scheme  of  promotional  and  fiscal  incentives  will  come  into  

operation with immediate effect and will remain in force for a period  

of five years.”  Besides this eligibility, facilities and tax relief etc. were  

also indicated.  The transmission of Electricity was to be undertaken  

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by the State Electricity Board and even the third party must be HT  

consumer  of  the  Board  unless  the  stipulation  was  specifically  

relaxed.  SEB was to purchase the electricity from the producer at  

the  minimum  specified  rate  without  any  restriction  on  time  or  

quantum  of  electricity.   Importantly,  Clause  3(iii)  of  the  policy  

guidelines suggested that the producer will have the option to sell the  

electricity generated by him to a third party at mutually agreed rates  

but within the State as per clause 1(i).  On or before 14th February  

1994 two projects, namely wind farm and mini hydel projects were  

transferred from Andhra Pradesh State Electricity Board to NEDCAP  

by the Government of Andhra Pradesh.  Later, vide letter dated 25th  

November,  1994  the  guidelines  as  indicated  in  the  letter  of  7th  

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September, 1993 were further clarified by the Government of India, in  

relation to fixation of purchase price for power produced from non-

conventional energy.  As per the guidelines commenting or clarifying  

the earlier guidelines it was stated that the base price applicable to  

non-conventional energy based power projects based on solar, wind  

small hydro, biomass etc. shall be equal to the base price of the year  

in which the PPAs are signed, clause 2 of the guidelines reads as  

under:

“A  promoter  /  developer  shall  be  entitled  to  receive the base price set out in PPA for all  electrical energy delivered from his project to  the State  grid for  the duration  of  the Power  Purchase Agreement.  The rate shall be equal  to base price in the year of signing of PPA,  escalated at a rate of 5% per year for a period  

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of 10 years,  from the date of  signing of  the  Power Purchase Agreement.  From the end of  the 10 years, and for the remaining duration  of  the Power Purchase Agreement,  the new  purchase price shall be equal to the purchase  price at the end of the 10th year, or the High  Tension  (HT)  tariff  prevalent  in  the  State  at  that time which is higher.”    

23. In  furtherance  of  the  decision  of  the  Govt.  of  India  and  the  

guidelines  published,  the  Govt.  of  Andhra  Pradesh  issued  two  

different GOs on which, the Tribunal as well as all the parties before  

us have placed heavy reliance.  They read as under:

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ENERGY (RES) DEPARTMENT

G.O.MS. NO: 93     DATED: 18-11-1997

ORDER:-

“In the reference 1st read above, the Ministry  of  Non-Conventional  Energy  Sources,  Government  of  India  have issued guidelines  

for  promotional  and  Fiscal  incentives  to  be  given  by  State  Government  for  power  generation  from  Non-Conventional  Energy  Sources.   The  incentives  are  envisaged  to  encourage  power  generation  in  the  Non- Conventional Sector which are renewable and  encouragement from the Government for this  Sector  is  necessary  in  view  of  the  fact  depletion  of  fossilfuels.   Further,  the  Renewable/  Non-Conventional  Energy  Sources are least pollution-effecting.

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In the G.O. third read above, the Government  have  accorded  certain  revised  incentives  in  respect  of  the  Developers  with  whom Non- Conventional  Energy  Development  Corporation  of  Andhra  Pradesh  had already  entered  into  Memoranda  of  Understanding  based on the guidelines existing prior to 15th  November, 1995.

While reviewing the incentives made available  

to  the  sectors,  certain  representations  were  received from some of the Non-Conventional  Energy Developers, and they have requested  for  extending  the  benefits  available  to  other  sectors.  

A review of the incentives made available to  various  sectors  of  non-conventional  energy  was  made  in  the  presence  of  official  from  Non-Conventional  Energy  Development  Corporation  of  Andhra  Pradesh  and  Andhra  

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Pradesh State Electricity Board, duly keeping  in  view  the  guidelines  of  Ministry  of  Non- Conventional Energy Sources, Government of  India, dated: 13-9-1993, a view was taken to  make available the incentives to all the Non- Conventional Energy Sources uniformly.

The Government after careful examination of  the  recommendations  and  with  a  view  to  encourage  generation  of  electricity  from  renewable sources of energy hereby allow the  

following uniform incentives to all the projects  based  on  renewable  sources  of  energy  viz.  Wind,  Biomass,  Co-generation,  Municipal  Waste and Mini Hydel :  

S.No. Description 1. Power  Purchase  

price Rs. 2.25

2. Escalation 5%  per  annum  with  1997-98  as  

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base  year  and  to  be  revised  on  1st  April of every year  upto the year 2000  A.D.

3. Wheeling Charges 2% 4. Third party sales Allowed at  a  tariff  

not lower than H.T.  tariff  of  A.P.S.E.  Board.

5. Banking Allowed  upto  12  

months (a) Captive consumption Allowed  

throughout  the  year  on  2%  banking charges.

(b) Third party sale Allowed  on  2%  banking  charges  from  August  to  March.

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This  order  issues  with  the  concurrence  of  Finance  &  Planning  (Fin.)  Department  vide  their  U.O.  No.  46291/351/EBS-EFES&T/97,  dated: 18.11.1997.

(BY ORDER AND  IN  THE NAME OF  THE  GOVERNOR OF ANDHRA PRADESH)

                                 V.S. SAMPATH SECRETARY TO GOVERNMENT

ENERGY (RES) DEPARTMENT

G.O. Ms. No. 112          Dated: 22.12.1998

ORDER:

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“In  the  Government  Order  cited,  certain  uniform  incentives  were  extended  to  the  Developers  of  Power  Projects  using  wind,  biomass co-generation, Municipal wastes and  mini hydel for promotion of and to encourage  generation  of  electricity  from  renewable  sources of energy.  In order to remove certain  ambiguities  in the implementation  of  uniform  incentives scheme and also to ensure that the  incentives  contemplated  are  channelled  for  promotion  and  development  of  non-

conventional energy sources, in keeping with  the  spirit  of  Government  Order  cited,  the  following amendments are issued:  

In the Government Order cited, certain  uniform  incentives  were  extended  to  the  Developers  of  Power  Projects  using  wind,  biomass co-generation, Municipal wastes and  mini hydel for promotion of and to encourage  generation  of  electricity  from  renewable  sources of energy.  In order to remove certain  

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ambiguities  in the implementation  of  uniform  incentives scheme and also to ensure that the  incentives  contemplated  are  channelled  for  promotion  and  development  of  non- conventional energy sources, in keeping with  the  spirit  of  Government  Order  cited,  the  following amendments are issued:

1. The uniform incentives specified in G.O. Ms.  No.93,  dated  18.11.1997  shall  be  available  only to the power projects where fuel used is  

from non-conventional  energy sources which  are  on  the  nature  of  renewable  sources  of  energy.

1. The operation of the incentives scheme shall  be watched for a period of 3 years and at the  end of 3 years period from the date of G.O.  Ms.  No.93  the  Andhra  Pradesh  State  Electricity Board shall  come up with suitable  proposals for review for further continuance of  the  incentives  in  the  present  form  or  in  a  

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suitable  modified  manner  to  achieve  the  objectives  of  promotion  of  power generation  through non-conventional sources.

1. Though there is a provision for banking and  third party sale, in the absence of conferring  the status of licences under Section 3 of the  Indian  Electricity  Act,  the  Entrepreneurs/  Developers of non-conventional energy power  may be handicapped  in  effecting  third  party  sales to the needy and contracted consumers.  

Therefore,  it  is  hereby  ordered  that  the  Entrepreneurs/Developers  covered  by  G.O.Ms. No.93, dated 18.11.1997 who made  the third party sale of energy shall be deemed  to be licencees for the purpose under Section  3 of the Electricity Duty Act,  1930 read with  Section 28 of Indian Electricity Act.”

(BY  ORDER  AND  IN  THE  NAME  OF  GOVERNOR OF ANDHRA PRADESH)

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S. SAMPATH SECRETARY TO GOVERNMENT

       24. These were the declarations or representations stated to have  

been  made by the  State  to  the  Developers.   The PPAs  between  

Transmission  Corporation  of  Andhra  Pradesh  Ltd.  and  the  

Developers were executed somewhere in May 1999 and some of the  

agreements  even  prior  thereto.   However,  despite  all  the  above  

guidelines and GOs, the Regulatory Commission passed an order on  

20th June, 2001 determining the tariff as well as defining other rights  

and  obligations  between  the  parties  including  that  the  generators  

were not permitted to make sale in favour of third party.  After the  

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passing of this order the Developers entered into PPAs between the  

period  August  2001  to  2002  and  confirmed  the  acceptance  and  

implementation  of  the  order  of  20th June,  2001.   While  providing  

different  clauses relating to various facets of sale and distribution of  

generated power, PPAs under Articles 2.1 and 2.2, which we have  

already  reproduced,  contemplate  specifically  that  the  purchase  of  

energy by APTRANSCO will  be at the tariff  provided under Article  

2.2.   Article  2.2  determines  the  rate  at  Rs.  2.25  per  unit  with  

escalation at 5% per annum with 1994-1995 as base year which is to  

be revised on 1st April of every year upto the year 2003-2004, beyond  

which  the purchase price by APTRANSCO will be decided by the  

Regulatory Commission.  Still  a further review of purchase price is  

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contemplated  on  completion  of  10  years  from  the  date  of  

commissioning  of  the  project  when it  will  be  reworked.   In  other  

words, there are specific stipulations provided under the PPAs, as  

well  as  in  the  order  dated  20th June,  2001,  for  revision/review of  

purchase price.  Clause 2.3 further clearly says that tariff is inclusive  

of  all  taxes,  duties  and levies.   In other  words,  all  the documents  

afore stated provide for a review including the guidelines issued by  

the Govt. of India.

25. At this stage, we may notice that these guidelines are general  

guidelines and every State was required to act as per its own needs,  

convenience and by taking a general view, as to, which are the most  

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practical and affordable projects and how they should be carried on  

by  the  State.   To  give  meaning  to  the  guidelines  that  they  were  

‘absolutely mandatory’, will not be in conformity with the law relating  

to interpretation of documents as well as according to the canons of  

exercise of executive and administrative powers.  These guidelines  

were certainly  required  to  be moulded by the  State  to  meet  their  

requirements depending on various factors prevailing in the State.

26. Now we will  proceed to  refer  to  the  various  legal  provisions  

relating  to  purchase  price  and/or  tariff  regulations.   The  principal  

central  legislation in this  regard is the Indian Electricity Act,  2003.  

Under  Section  3,  a  national  electricity  policy  and  plan  has  to  be  

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prepared by the Central Government which has to be notified.  This  

plan itself  can be reviewed or revised by the appropriate authority  

under the Act.  Section 8 of the Electricity Act, 2003 requires every  

State  to  notify  and  constitute,  for  the  purposes  of  this  Act,  a  

Commission  for  the  State  to  be  known  as  Electricity  Regulatory  

Commission  of  that  State.   Section  86  of  this  Act  spells  out  the  

functions of the State Commission.  Under Section 86(1)(a) it is to  

determine the tariff for generation, supply, transmission and wheeling  

of electricity,  wholesale, bulk and retail,  as the case may be.  It  is  

also  to  regulate  electricity  purchase  and  procurement  process  of  

distribution licencees including the price at which electricity shall be  

procured from the generating companies or licensees or from other  

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sources through agreements for purchase of power for distribution  

and supply within the State as per Section 86(1)(b).  Section 86(1)(d)  

empowers this Commission to issue licences to persons seeking to  

act  as  transmission licensees,  distribution  licensees and electricity  

traders  with respect to their operations within the State.  Besides its  

advisory functions it has also been given the general /residue powers  

to do all other functions in terms of Section 86(1)(k).  Sections 61 to  

64  of  the  Electricity  Act,  2003  place  an  obligation  upon  the  

appropriate  Commission  to  determine the tariff  in accordance  with  

the provisions of this Act.  An application for determination of tariff  

shall be made by the generating company under Section 64 and the  

tariff has to be determined by the appropriate Commission and it is  

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also required to specify the terms and conditions for determination of  

the  tariff  as  per  the  factors  and  the  guidelines  specified  under  

Section 61 of the Act.

27. The Reform Act, 1998 was enacted, primarily, with the object of  

constituting two separate corporations; one for generation and other  

for transmission and distribution of electrical energy.  The essence  

was  restructuring,  so  as  to  achieve  the  balance  required  to  be  

maintained in regard to competitiveness and efficiency on the one  

part and the social objective of ensuring a fair deal to the consumer  

on the other.   This Act  is also intended for creation of a statutory  

regulatory authority.  Section 3 of the Act requires the State Govt. to  

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establish  by  notification  a  Commission  to  be  known  as  Andhra  

Pradesh  Electricity  Regulatory  Commission.   This  was  done  by  

notification  dated  3rd April,  1999.   As  already  noticed,  section  11  

detailed the functions of the Regulatory Commission and primarily it  

had  advisory  as  well  as  regulatory  functions.  In  terms  of  Section  

11(1)(c)  it  was  required  to  issue  licenses  in  accordance  with  the  

provisions of the Act and determine the conditions to be included in  

the license.  However, 11(1)(e) gave it much wider power and duty to  

regulate   the  purchase,  distribution,  supply  and  utilization  of  

electricity,  the  quality  of  service,  the  tariff  and  charges  payable  

keeping in view  both the interest  of  the consumer as well as the  

consideration that the supply and distribution cannot be maintained  

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unless the charges for the electricity supplied are adequately levied  

and duly collected.  In terms of Section 11(1)(l) it was to  undertake  

all incidental or ancillary things to the functions assigned to it under  

the provisions of the Act.  Section 12 of the Act vests the State Govt.  

with  the  power  to  issue  policy  directions  on  matters  concerning  

electricity  in  the  State  including  the  overall  planning  and  co-

ordination.   All policy directions shall  be issued by the State Govt.  

consistent  with the objects sought to be achieved by this Act and,  

accordingly, shall not adversely affect or interfere with the functions  

and powers of the Regulatory Commission including, but not limited  

to, determination of the structure of tariffs for supply of electricity to  

various classes of consumers.  The State Govt. is further expected to  

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consult  the  Regulatory  Commission  in  regard  to  the  proposed  

legislation or rules concerning any policy direction and shall duly take  

into account the recommendation by the Regulatory Commission on  

all  such matters.  Thus the scheme of these provisions is to grant  

supremacy  to  the  Regulatory  Commission  and  the  State  is  not  

expected  to  take  any  policy  decision  or  planning  which  would  

adversely  affect  the  functioning  of  the  Regulatory  Commission  or  

interfere  with its  functions.   This provision also clearly implies that  

fixation of tariff is the function of the Regulatory Commission and the  

State Govt. has a minimum role in that regard.  Chapter VII of this  

Act  deals  with  tariff.   In  terms  of  Section  26(2),  the  Regulatory  

Commission, in addition to its power of issuing licence, is entitled to  

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fix terms  and  conditions  for  determination  of  the  licensee’s  

revenue and tariffs  by regulations  which are to be duly published.  

The expression ‘tariff’ has not been defined in any of the Acts, with  

which we are concerned in the present appeals, despite the fact that  

the  expression  ‘tariff’  has  been used  repeatedly in  both  the  Acts.  

Under the Electricity Act,  2003 ‘tariff’  has neither been defined nor  

explained in  any of  the  provisions  of  the  Act.   Explanation  (b)  to  

Section 26 of the Reform Act, 1998 states what is meant by ‘tariff’.  

This provision states that ‘tariff’ means a schedule of standard price  

or  charges  or  specified  services  which  are  applicable  to  all  such  

specified  services  provided  to  the  type  or  types  of  customers  

specified in the ‘tariff’ notification. This is an explanation to Section  

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26 which deals with licenses, revenues and tariffs.  In other words,  

this explanation may not be of greater help to the Court in dealing  

with  the  case  of  generating  companies.   Similarly,  the  expression  

‘purchase price’ has neither been defined nor explained in any of the  

afore-stated Acts.

28. Therefore,  in the absence of any specific  definition in any of  

these Acts we will  have to depend upon the meaning attached to  

these  expressions  under  the  general  law or  in  common parlance.  

The expression ‘tariff’  has been explained in the Law Lexicon with  

legal  Maxims,  Latin  terms and Words  & Phrases  (Second  Edition  

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1997) as “determination, ascertainment, a table of rates of export and  

import duties, in which sense the word has been adopted in English  

and other European languages and as defined by the law dictionaries  

the word ‘tariff’ is a cartel of commerce; a book of rates; a table or  

catalogue, drawn usually in alphabetical order, containing the names  

of several kind of merchandise, with the duties or customs to be paid  

for  the  same  as  settled  by  the  authority  or  agreed  between  the  

several princes and States that hold commerce together.”

29. It has also been explained as a schedule, system, or scheme of  

duties imposed by the Government of a country upon goods imported  

or exported; published volume of rate schedules and general terms  

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and conditions under which a product or service will be supplied; a  

document approved by the responsible regulatory agency listing the  

terms  and  conditions  including  a  schedule  of  prices,  under  which  

utility services will be provided.  The expression ‘purchase price’ has  

to be given its limited meaning, i.e. the price paid for purchasing a  

good  and  in  the  context  of  the  present  case,  price  at  which  

generated electricity will be sold to the specified agencies.  The term  

‘purchase price’ indicated in the PPAs, as such, would be a matter  

within the realm of contract but this is subject to the changes which  

are contractually and/or even statutorily permissible.  Purchase price  

ultimately would form part of the tariff, as tariff relatable to a licensee  

or  a  consumer  would  have  essentially  taken  into  account,  the  

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purchase price.  The purchase price may not include tariff but tariff  

would always or is expected to include purchase price.  

30. The Regulatory Commission is  vested with very vast  powers  

and functions. Section 11 of the Reform Act, 1998 declares fixation  

of tariff as one of the primary functions of the Regulatory Commission  

in  general  more  particularly,  to  the  specified  consumers  under  

Section 26 of the Reform Act, 1998.  While under the Electricity Act,  

2003, Sections 61 and 62 read with Section 86 (1)(a)(b)  deal with  

fixation  of  tariffs  in  relation  to  production,  distribution  and  sale  of  

generated  power  to  the  end  consumer.   These  provisions  clearly  

demonstrate  that  the  Regulatory  Commission  is  vested  with  the  

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function for determining the tariff for generation, supply, transmission  

and  billing  of  electricity  etc.,  as  well  as  regulation  of  electricity  

purchase  and  procurement  process  of  distribution  licensees,  

including  price  at  which  electricity  shall  be  procured  from  the  

generating  companies.   With  these  specific  powers  in  the  statute  

book  itself,  it  cannot  be said  that  procurement  of  power from the  

generating  companies  will  not  fall  within  the  ambit  of  powers and  

functions of the Regulatory Commission.  It,  as already noted,  is a  

common body performing  functions,  duties  and exercising  powers  

under all these three Acts.  This Court had the occasion to deal with  

somewhat similar issues in the case of PTC India Ltd.   v. Central  

Electricity Regulatory Commission [(2010) 4 SCC 603].  The Court  

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was, amongst others, dealing with the provisions of Sections 61 to 63  

of  the  Electricity  Act,  2003  and  regulation  making  power  of  the  

Regulatory Commission.  The Court was concerned with other issues  

as  well  including  the  powers  of  the  Tribunal  in  relation  to  judicial  

review etc. but it will be of assistance to us to notice that the Court  

referred  to  different  kinds  of  delegated  legislations  under  the  

provisions of Electricity Act, 2003 and with regard to the power of the  

Regulatory Commission and the scope of the term ‘tariff’  the Court  

held as under:

“23.  Section  52  of  the  2003  Act  deals  with  trading  of  electricity  activity.   Under  Section  52(1),  the  appropriate  Commission  may  specify  the  technical  requirement,  capital  adequacy  requirement  and  creditworthiness  

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for being an electricity trader.  Under Section  52(2), every trader is required to discharge its  duties,  in  relation  to  supply  and  trading  in  electricity,  as  may  be  specified  by  the  appropriate Commission.

24.  The  standards  of  performance  of  licensee(s)  may  be  specified  by  the  appropriate Commission under Section 57 of  the Act.

25.  The  2003  Act  contains  separate  provisions  for  the  performance  of  dual  functions by the Commission.  Section 61 is  the  enabling  provision  for  framing  of  regulations  by  the  Central  Commission;  the  determination of terms and conditions of tariff  has been left to the domain of the Regulatory  Commissions  under  Section  61  of  the  Act  whereas  actual  tariff  determination  by  the  Regulatory  Commissions  is  covered  by  Section  62  of  the  Act.   This  aspect  is  very  

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important  for  deciding  the  present  case.  Specifying  the  terms  and  conditions  for  determination of tariff is an exercise which is  different  and  distinct  from  actual  tariff  determination  in  accordance  with  the  provisions of  the Act  for supply of  electricity  by  a  generating  company  to  a  distribution  licensee or for transmission of electricity or for  wheeling  of  electricity  or  for  retail  sale  of  electricity. 26. The term “tariff” is not defined in the 2003  

Act.  The term “tariff” includes within its ambit  not only the fixation of rates but also the rules  and  regulations  relating  to  it.   If  one  reads  Section 61 with Section 62 of the 2003 Act, it  becomes  clear  that  the  appropriate  Commission shall determine the actual tariff in  accordance  with  the  provisions  of  the  Act,  including the terms and conditions which may  be specified  by the appropriate  Commission  under Section 61 of the said Act.  Under the  2003 Act, if one reads Section 62 with Section  

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64,  it  becomes  clear  that  although  tariff  fixation  like  price  fixation  is  legislative  in  character,  the  same under  the  Act  is  made  appealable  vide  Section  111.   These  provisions,  namely,  Section  61,  62  and  64  indicate  the  dual  nature  of  functions  performed  by  the  Regulatory  Commissions  viz. decision-making and specifying terms and  conditions for tariff determination.

27. Section 66 confers substantial powers on  

the  appropriate  Commission  to  develop  the  relevant  market  in  accordance  with  the  principles of competition, fair participation as  well  as  protection  of  consumers’  interests.  Under  Sections  111(1)  and  111(6)  respectively,  the  Tribunal  has  appellate  and  revisional  powers.   In  addition,  there  are  powers  given  to  the  Tribunal  under  Section  121  of  the  2003  Act  to  issue  orders,  instructions or directions, as it may deem fit,  to  the  appropriate  Commission  for  the  

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performance of statutory functions under the  2003 Act.”

31. Similarly, another Bench of this Court in the case of Tata Power  

Company Ltd.  v. Reliance Energy Ltd., [2009 (7) SCALE 513], was  

primarily, concerned with the role of the generating companies and  

their right to make choice to sell power to any person or licensee and  

while referring to the concept of open access, the Court in para 59 of  

the judgment referred to the issues arising in the case which read as  

under:

“Although before us a large number of  contentions  had  been  raised,  the  core  questions,  which arise for  our  consideration,  are:-

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(A) Whether  recourse  to  Section  23 of  the  Act  can  be  taken  for  issuance  of  any  direction  to  the  generating  company?

(B) Whether  the  Commission  while  applying  the  provisions  of  Section 86(1)(b) of the Act  could also take recourse to  Sections  23  and  60  thereof?

(C) Whether  equitable  allocation  of  power  generated  by  a  generating  company is permissible?”

32. In  the  present  case  we  are,  primarily,  concerned  with  the  

answers given by the Court to questions (A) and (B) framed therein,  

the  discussion  on the  subject  and finally  the  relevant  conclusions  

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drawn  by  the  Court  in  para  140  to  142.   The  Court  elaborately  

discussed  the  matter  including  the  fact  that  some  generating  

companies had entered into PPAs while other had not.  The Court,  

amongst others, declare the following conclusions (of which we refer  

only the relevant portions):

“7) if regulatory clause is sought to be applied  

in  relation  to  allocation  of  power,  the  same  would  defeat  the  de-licensing  provisions.  Generating  companies  have  the  freedom to  enter into contract and in particular long term  contracts with a distribution company subject  to the regulatory provisions contained in the  2003 Act.

8)  PPA  for  a  long  term  is  essential  for  increasing  and  decreasing  the  capacity  of  

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generation  of  electricity  by  the  generating  company,  which  purpose  by  the  2003  Act  must be allowed to achieve.

13) Section 86(1)(b) of the 2003 Act clearly  shows that the generating company indirectly  comes  within  the  purview  of  regulatory  jurisdiction as and when directions are issued  to  the  distributing  companies  by  the  appropriate Commission but the same would  

not  mean  that  while  exercising  the  said  jurisdiction,  the Commission will  bring within  its umbrage the generating company also for  the purpose of issuance separate direction.”

33. In addition to the statutory provisions and the judgments afore  

referred,  we  must  notice  that  all  the  PPAs  entered  into  by  the  

generating  companies  with  the  appropriate  body,  as  well  as  the  

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orders issued by the State in GO Ms. Nos. 93 and 112, in turn, had  

provided for review of tariff and the conditions.  The Tribunal appears  

to have fallen in error of  law in coming to the conclusion that  the  

Regulatory Commission had no powers either in law or otherwise of  

reviewing the  tariff  and so  called  incentives.   Every document  on  

record  refers  to  the  power  of  the  authority/Commission  to  take  a  

review on all aspects including that of the tariff. One of the relevant  

consideration  for  determining  the  question  in  controversy  is  to  

examine whether the matter falls within the statutory or contractual  

domain.  From various provisions and the documents on record it is  

clear that Regulatory Commission is vested with the power to revise  

tariff  and  conditions  in  relation  to  procurement  of  power  from  

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generating companies.  It is also clear from the record that in terms  

of the contract between the parties, the APTRANSCO had reserved  

the  right  to  revise  tariff  etc.  with  the  approval  of  the  Regulatory  

Commission.

34. With  some  emphasis,  the  parties  had  argued  the  question  

relating to ‘estoppel’ and ‘legitimate expectation’ with reference to the  

facts of the present case.  The contention is raised that by the GOs  

issued by the State Government as well as the letters of the ministry  

a  representation  was made by the  Government  to  the  generating  

companies and they, having altered their positions, have a right to  

compel  the  State  Government  and the  Regulatory Commission  to  

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abide by those terms for ever and it  is their legitimate expectation  

that State is required to comply with those conditions and no other.

35. For proper analysis of the submissions made by the parties, it  

is necessary for us to examine on what premises the appellants had  

claimed  and  the  Tribunal  has  accepted  the  plea  of  estoppel.  

Admittedly, this all begins with the letter dated 7th September, 1993  

issued  by  the  Government  of  India,  Ministry  of  Non-Conventional  

Energy Sources, New Delhi to the Chief Secretary of the respective  

States.  In this letter, the new strategy action plan of the Ministry in  

relation  to  generation  of  grid  quality  power  from non-conventional  

energy sources was mentioned in some elaboration and the Ministry  

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had referred to the fact that it had drawn certain guidelines and also  

indicated the minimum buy-back price of Rs. 2.25 per unit which was  

proposed by the Ministry and it was based upon the average cost of  

generation, as noticed by the authorities, at the relevant point of time.  

These  guidelines  were  to  constitute  an  attractive  package  to  

encourage private sector and the respective States were required to  

examine and alter or amend the same as conducive to a particular  

State.   Hereafter,  a  letter  dated  25th November,  1994  was  again  

issued  by  the  Ministry  to  the  Managing  Director  of  the  Non-

Conventional  Energy  Development  Corporation,  Andhra  Pradesh  

annexing the guidelines which were subject to be amended.  These  

guidelines  itself  showed  that  Electricity  Board,  which  was  the  

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competent  authority  at  that  relevant  point  of  time,  to  announce  a  

‘base purchase price’ every year for electrical energy purchased by  

the Board from the non-conventional energy based projects.  These  

guidelines contemplated that the base price shall be escalated at a  

minimum  rate  of  5%  every  year.   Clause  2  of  the  Guidelines  

stipulated that the promoter or a developer shall be entitled to receive  

the base price set out in the PPA for all electrical energy delivered for  

the duration of the PPA.  The rate shall be equal to the base price in  

the year of signing of PPA, escalated at the rate of 5% per year for a  

period  of  ten  years  from  the  date  of  signing.   Thereafter  new  

purchase price will be fixed as per the tariff prevalent in the State at  

the relevant time.  Thereafter, the Andhra Pradesh Government has  

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issued GO Ms. No. 93 dated 18th November, 1997 referring to certain  

incentives required to be given to the projects.  These incentives only  

referred  to  the  power purchase  price,  escalation  of  5% with base  

year 1997-98, wheeling charges, third party sales allowed to a limited  

extent.   These, again,  were the guidelines which,  in fact,  we have  

referred to in great detail above and were primarily intended to guide  

the States in taking the respective decisions in that behalf.   Again  

vide GO. Ms. No. 112 dated 22nd December, 1998 referring to the  

extension of all these uniform incentives, certain amendments were  

carried out to GO Ms. No. 93 dated 18th November, 1997.  Clause 2  

of this order referred that the operation of the incentive scheme shall  

be watched for a period of three years and at the end of three years  

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the Electricity Board shall come up with suitable proposals for review  

for  further  continuance  of  the  incentives  in  that  form,  or  to  be  

modified  suitably.   Keeping these guidelines  in mind,  the State  of  

Andhra Pradesh vide GO Ms. No. 93 dated 18th November,  1997,  

while referring to the guidelines issued by the Government of India  

for  promotional  and  fiscal  incentives,  noticed  the  various  

representations which were received from Non-conventional Energy  

Developers for extension of benefits as afore-referred in relation to all  

non-conventional energy resources uniformly.  Thereafter, the parties  

took  up  the  matter  for  annual  consideration,  which  exercise  was  

undertaken by them in terms of the guidelines issued by the State  

and the Central Government.  State of Andhra Pradesh reiterated the  

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incentives and directed that the same would continue for a period of  

three years in terms of GO Ms. No. 93, whereafter it will be reviewed.  

The incentives relied upon, on the basis of the guidelines and the  

issued  Government  orders  are  primarily,  related  to  fixation  of  

purchase  price  of  the  generated  power  from  Non-Conventional  

developer/generators and sale of such energy to third parties.  In the  

meanwhile, Regulatory Commission had been established under the  

provisions of  the Reform Act,  1998.   This Regulatory Commission  

was to take over all the functions of the said Electricity Board as well  

as  other  authorities  for  generation,  distribution  and  other  matters  

relating to electricity in the State.  This resulted in initiation of  suo  

motu  proceedings by the Regulatory Commission for determination  

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and fixation of tariff, which after hearing the parties finally passed the  

order dated 20th June, 2001.  This order as we have already noticed  

was accepted by all the parties and has not been questioned till date.  

This order provided for certain variations in the incentives, which as  

already noticed, are related to the fixation of tariff or purchase price  

and as stipulated, the Commission considered all objections at some  

length  and  ordered  that  power  generated  by  Non-conventional  

Energy Developers is not permitted to be sold to third parties and  

price  was kept  at  Rs.  2.25  per  unit  price  with  5% escalation  per  

annum with 1994-95 as the base year.  The parties had entered into  

agreements i.e.  PPAs at different  times after  passing of this order  

between June, 2001 to August, 2001 and even thereafter.  Thus, at  

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that time, the entire matter between the parties was controlled by the  

PPAs which fully contemplated that all  the delivered energy at the  

interconnection point for sale to TRANSCO will be purchased at the  

tariff provided under Article 2.2 which in turn confirmed the order of  

20th June, 2001 in that regard and it was stated that the matter will be  

reviewed in April, 2004 and it could also be reviewed after 10 years  

from the date of commissioning of the project.  This PPA as well as  

the order passed by the Regulatory Commission in the year 2001  

remained  in  force  without  being  questioned  in  any  manner  

whatsoever before any competent forum and in any case, not to any  

benefit of respondents.  Then came the order dated 20th March, 2004  

passed by the Regulatory Commission again, by initiating  suo motu  

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proceedings.  In this order, the Commission had retained the basic  

unit price of 2.25 as on 1st April, 1994 and the escalation index of 5%  

per annum which was to be simple and not compounded every year.  

In other words, on 1st April, 2001 the price was 3.37/kwh in relation to  

Wind  Power  Purchasers.   Except  varying  this  price,  the  order  of  

2004, in turn, had reiterated the contents of the order of 2001 which,  

as already noticed,  has attained finality.   Another  factor  which we  

may notice is that in its order dated 7th July, 2004, while clarifying its  

order dated 20th March 2004, the Commission has clearly observed:

“12. It  is  relevant to clarify  that  by the  order  dated  20-03-2004,  the  Commission  is   not  mandating  in  any  manner  those  NCE  developers who have not accepted the earlier   order  dated  20-06-2001  passed  by  the   

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Commission,  while  their  challenge  to  the  order  is  pending  the  decision  by  the  High  Court.  However, such of the NCE developers   who had accepted the earlier order dated 20- 06-2001  and  have  been  selling  electricity   generated  by  them to  APTRANSCO cannot   challenge the jurisdiction of the Commission  to  review  the  terms  as  per  the  stipulation   contained in the order dated 20-6-2001.”

36. On the basis  of  this  factual  matrix,  the respondents  claimed  

that  the  State  Government  and  the  Regulatory  Commission  both  

were bound to continue the incentives as were provided to them in  

furtherance to the letters and orders of Central as well as the State  

Governments  discussed  above.  They  have  a  legitimate  right  to  

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expect that these incentives were to be continued indefinitely in the  

same  manner  and  the  authorities  concerned  are  estopped  from  

altering the rates and/or imposing the condition of no sale to third  

parties.  We are unable to find any merit in this contention.  In our  

view, the Tribunal has erred in law in treating these  inter-se letters  

and guidelines between the Government of India, State Government  

and  the  Commission/the  State  Electricity  Board  as  unequivocal  

commitments  to  the  respondent/purchasers/generators/developers  

so as to bind the State for all times to come.  For the principle of  

estoppel to be attracted, there has to be a definite and unambiguous  

representation to a party which then should act thereupon and then  

alone the consequences in law can follow.  In the present case, the  

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policy  guidelines  issued  by  the  Central  Government  were  the  

proposals  sent  to  the  State  Government,  which  the  State  

Government accepted to consider, amend or alter as per their needs  

and  conditions  and  then  make  efforts  to  achieve  the  objects  of  

encouraging Non-conventional Energy Generator and Purchasers to  

enter into this field.  These are the matters, which will squarely fall  

within  the  competence  of  the  Regulatory  Commission/the  State  

Electricity Board at the relevant points of time.  Besides that, there  

was no definite  and clear  promise made by the authorities  to  the  

developers that  would invoke the principle  of  promissory estoppel.  

Undoubtedly, to encourage participation in the field of generation of  

energy  through  non-conventional  methods,  some  incentives  were  

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provided but these incentives under the guidelines as well as under  

the PPAs signed between the parties from time to time were subject  

to review.  In any case, the matter was completely put at rest by the  

order  of  20th June,  2001  and  the  PPAs  voluntarily  signed  by  the  

parties  at  that  time,  which had also provided such stipulations.   If  

such stipulations were not  acceptable to the parties  they ought  to  

have raised objections at that  time or at least  within a reasonable  

time thereafter.  The agreements have not only been signed by the  

parties but they have been fully acted upon for a substantial period.  

We have already referred to various statutory provisions where the  

Regulatory Commission  is  entitled  to  determine  the  tariff.   In  this  

situation we are unable to agree with the view taken by the Tribunal  

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that Regulatory Commission had no jurisdiction and that fixation of  

tariff does not include purchase price for buy back of the generated  

power.

37. The principle of promissory estoppel, even if, it was applicable  

as such, the Government can still show that equity lies in favour of  

the Government and can discharge the heavy burden placed on it.  In  

such circumstances, the principle of promissory estoppel would not  

be enforced against the Government as it is primarily a principle of  

equity.   Once the  ingredients  of  promissory  estoppel  are satisfied  

then it could be enforced against the authorities including the State  

with very few extra ordinary exceptions to such enforcement.  In the  

United  States  the  doctrine  of  Promissory  Estoppel  displayed  

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remarkable vigor and vitality but it is still developing and expanding.  

In India, the law is more or less settled that where the Government  

makes a promise knowing or intending that it would be acted upon by  

the promissory and in fact the promissory has acted in reliance of it,  

the Government may be held to be bound by such promise.  It is a  

settled canon of law that doctrine of promissory estoppel is not really  

based on principle of estoppel but is a doctrine evolved by equity in  

order to prevent injustice.  There is no reason why it should be given  

only a limited application by way of defence.  It can also be the basis  

of a cause of action.  Even if we assume that there was a kind of  

unequivocal  promise  or  representation  to  the  respondents,  the  

reviews have taken place only after the period specified under the  

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guidelines  and/or  in  the PPAs was over.   This  is  a matter  which,  

primarily,  falls  in  the  realm  of  contract  and  the  parties  would  be  

governed by the  agreements  that  they have signed.   Once  these  

agreements  are  singed  and  are  enforceable  in  law  then  the  

contractual obligations cannot be frustrated by the aid of promissory  

estoppel.

38. Following the judgment of this Court  in the case of Union of  

India  v.  M/s.  Indo-Afghan  Agencies  Ltd.  [(1968)  2 SCR 366],  this  

Court in the case of Century Spinning and Manufacturing Company  

Ltd. v. The Ulhasnagar Municipal Council [(1970) 1 SCC 582] held  

that if the promise is made in regard to a present or existing fact, the  

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principle of estoppel can be enforced against the Government.  But a  

promise in relation to a future transaction or act may not fall within  

the ambit  of  promissory estoppel.   This law was further  discussed  

with some elaboration by the Court in the case of Motilal Padampat  

Sugar Mills. Co. Ltd. v. State of Uttar Pradesh [(1979) 2 SCC 409],  

where the Court after considering the position of law in England and  

United States and comparing the same to the Indian Law, laid down  

the basic  concept  of  promissory estoppel  that  would determine its  

enforceability.  In the case of Pawan Alloys v. UPSEB [(1997) 7 SCC  

251],  the  Court,  though  had  enforced  the  principle  of  promissory  

estoppel against the Board, but certain basic facts of that case needs  

to  be  noticed  by  us.    The  appellants  in  that  case  had  neither  

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expressly nor impliedly stated that it has the power to withdraw the  

incentives and rebate at a time prior to the expiry of three years for  

which  it  was granted.   Secondly,  none  of  the  private  parties  had  

voluntarily or even by remotest choice agreed to give up the benefits  

given to them by clear representation held out by the Board.  As is  

obvious, the power of the Board to increase the general tariff  was  

accepted, but the incentive of rebate was de horse the tariff and thus,  

promissory estoppel was enforceable against the Board.

39. Another  very important  dictum of  the  Court  in  this  judgment  

was  that  the  power  of  the  Board  to  fix  general  tariff  as  well  as  

discharge of other related functions was held to be quasi-judicial in  

character.  This power of the Board is exercised under the statute as  

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a power-cum-duty and is  independent  of  granting  or  declining any  

rebate.  In the present case the order dated 20th June, 2001 was fully  

accepted by the parties without any reservation.  After the lapse of  

more  than  reasonable  time  of  their  own  accord  they  voluntarily  

signed the PPA which contained a specific stipulation prohibiting sale  

of generated power by them to third parties.   The agreement also  

had renewal clause empowering TRANSCO/APTRANSCO/Board to  

revise the tariff.  Thus, the documents executed by these parties and  

their conduct of acting upon such agreements over a long period, in  

our  view,  bind  them  to  the  rights  and  obligations  stated  in  the  

contract.  The parties can hardly deny the facts as they existed at the  

relevant time, just because it may not be convenient now to adhere  

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to those terms.  Conditions of a contract cannot be altered/avoided  

on  presumptions  or  assumptions  or  the  parties  having  a  second  

thought that a term of contract may not be beneficial to them at a  

subsequent stage.  They would have to abide by the existing facts,  

correctness of which, they can hardly deny.  Such conduct, would be  

hit by allegans contraria non est audiendus.

40. Lastly, we may refer to a more recent judgment of this Court.  

In the case of Kusumam Hotels (P) Ltd.  v. Kerala Seb [(2008) 13  

SCC  213],  where  the  Court  discussed  in  some  elaboration  the  

different judgments of this Court on the subject and then declined to  

enforce  the  principle  of  promissory  estoppel  as  there  was  no  

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foundational facts and also indicated that the Government can alter,  

amend or rescind its policy decision in public interest, the Court held  

as under:

“27. Yet again in U.P. Power Corpn. Ltd. v.  Sant  Steels  &  Alloys  (P)  Ltd.,  it  was  held:  (SCC p.800, para 27)

“27. In this background, in view of various  

decisions noticed above, it will appear that the  Court’s approach in the matter of invoking the  principle of  promissory estoppel  depends on  the  facts  of  each  case.  But  the  general  principle  that  emerges  is  that  once  a  representation has been made by one party  and  the  other  party  acts  on  that  representation  and  makes  investment  and  thereafter  the  other  party  resiles,  such  act  cannot  be stated  to  be fair  and reasonable.  When  the  State  Government  makes  a  representation  and invites  the  entrepreneurs  by showing various benefits  for  encouraging  

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to  make  investment  by  way  of  industrial  development of the backward areas or the hill  areas,  and  thereafter  the  entrepreneurs  on  the representations so made bona fide make  investment  and  thereafter  if  the  State  Government resiles from such benefits, then it  certainly  is  an  act  of  unfairness  and  arbitrariness. Consideration of public interest  and the fact that there cannot be any estoppel  against a statute are exceptions.”

xxx xxx xxx

36. The law which emerges from the above  discussion is that the doctrine of promissory  estoppel  would  not  be  applicable  as  no  foundational fact therefor has been laid down  in a case of this nature. The State, however,  would be entitled to alter, amend or rescind its  policy  decision.  Such  a  policy  decision,  if  taken in public interest, should be given effect  to. In certain situations, it may have an impact  from a retrospective effect  but  the same by  itself would not be sufficient to be struck down  on  the  ground  of  unreasonableness  if  the  source  of  power is  referable  to  a statute  or  statutory  provisions.  In  our  constitutional  scheme,  however,  the  statute  and/or  any  

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direction  issued  thereunder  must  be  presumed  to  be  prospective  unless  the  retrospectivity is indicated either expressly or  by necessary implication.  It  is  a  principle  of  the rule of law. A presumption can be raised  that a statute or statutory rule has prospective  operation only.”

41. In  our  country,  the  law of  promissory  estoppel  has  attained  

certainty.  It is only an unambiguous and definite promise, which is  

otherwise  enforceable  in  law upon  which,  the  parties  have acted,  

comes within the ambit  and scope of enforcement  of this principle  

and binding on the parties for their promise and representation.  It will  

be  difficult  for  the  Court  to  hold  that  the  guidelines  can  take  the  

colour  of  a  definite  promise  which  in  the  letters  of  the  Central  

Government itself were proposals to the State Government.  Besides  

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that, if for the sake of argument, we treat the State letters/circulars as  

promise  or  representations  to  the  private  parties  like  the  

respondents,  even  then,  they  led  to  the  execution  of  a  definite  

contract between the parties which will purely fall  in the domain of  

contractual law.  These contracts specifically provided for review and  

when reviewed in the year 2001 parties not only accepted the order  

but  executed  contracts  (PPAs)  in  furtherance  of  it.  In  these  

circumstances, we are unable to accept the argument that the State  

or  the  Regulatory Commission  or  erstwhile  State  Electricity  Board  

were bound to allow same tariff and permit third party sales for an  

indefinite period.  To this extent, authorities, in any case, would not  

be bound by the principle of estoppel.

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42. Now, we will proceed to examine the merits or otherwise of the  

findings  recorded  by the  Tribunal  that  the  PPAs  executed  by  the  

parties,  were result  of  some duress  and thus,  it  will  not  vest  the  

authorities  with  the  power  to  review  the  tariff  and  other  granted  

incentives.   PPAs  were  executed  prior  and  subsequent  to  the  

issuance  of  the  order  dated  20th June,  2001.   Different  persons  

executed  the  contracts  at  different  times  in  full  awareness  of  the  

terms and conditions of such PPA.  To frustrate a contract  on the  

ground  of  duress  or  coercion,  there  has  to  be  definite  pleadings  

which  have  to  be  substantiated  normally  by  leading  cogent  and  

proper evidence.  However, in the case where summary procedure is  

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adopted like the present one, at least some documentary evidence or  

affidavit  ought  to  have  been  filed  raising  this  plea  of  duress  

specifically.  From the record before us, nothing was brought to our  

notice  to  state  the  plea  of  duress  and  to  prove the  alleged  facts  

which  constituted  duress,  so  as  to  vitiate  and/or  even  partially  

reduce,  the  effect  of  the  PPAs.   On  the  one  hand,  the  Tribunal  

appears to have doubted the binding nature of the contracts stating  

that it  contained unilateral  conditions introduced by virtue of Order  

and approval of the Regulatory Commission, while on the other hand,  

in para 53 of the Order, it proceeded on the presumption that PPAs  

are final and binding and still drew the conclusion that the Regulatory  

Commission could not revise the tariff.  Even in the order, no facts  

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have  been  pointed  out  which,  in  the  opinion  of  the  Tribunal,  

constituted duress within the meaning of the Contract Act so as to  

render  the  contract  voidable.   Another  aspect  of  the  entire  

controversy  is  that  none  of  the  generators  had  challenged  the  

agreements and in fact, except in arguments before the Tribunal no  

case was made out for the purposes of vitality of the contract or any  

part  thereof.   On  the  contrary,  all  the  generators  under  all  the  

branches of Non-Conventional Energies, have accepted the contract  

and proceeded on the basis that the said contracts are binding and  

still  the  Regulatory  Commission  does  not  have  any  power  or  

jurisdiction to revise the tariff  or deal with the concessions.   If  the  

contracts  are  a  result  of  duress  and  cannot  be  given  effect,  the  

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results could be disastrous for both the sides.  If a contract suffers  

from the defect  of undue influence or duress,  as the case may be  

then the consequences in law should follow. It is a settled canon of  

law  that  when  the  consent  to  agreement  is  caused  by  undue  

influence the agreement is a contract voidable at the option of the  

parties  whose  consent  was  so  caused.   Even  if  such  party  had  

received any benefit under the terms of the contract the Court could  

still pass orders as to the voidability or otherwise of the contract but  

upon such terms and conditions as the Court may deem just.  Undue  

influence  or  duress  is  said  to  be  subtle  of  the  fraud  whereby  

mysteries burden over the mind of a victim by insidious approaches.  

Firstly,  there are no facts on record,  much less, supported by any  

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documentary  or  any  other  evidence  to  sustain  the  plea  that  the  

contracts (PPAs) are a result  of  undue influence or duress by the  

State or its agencies upon the generators.  Secondly, the generators  

have already taken benefit of that contract which was based on the  

policy  of  the  State  as  well  as  the  order  of  the  Regulatory  

Commission.  Having attained those benefits, it will hardly be of any  

help to the appellants, particularly, in the facts and circumstances of  

the case, to substantiate, justify or argue the plea of duress.

43. In the case of  Birla Jute Manufacturing  Co. v.  State of  M.P.  

[(2002) 9 SCC 667], the Supreme Court was concerned with a case  

where validity of undertaking given under duress was the plea taken  

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by the appellant.  This pleading on the same merits and noticing the  

material, like the present case, the Court held as under:

“2.  Learned  counsel,  appearing  for  the  appellant urged that the undertaking given by  the  appellant  Company  was  under  duress  and, therefore, it is not an undertaking in the  eyes of law and the appellant is not liable to  pay  the  water  charges  under  such  circumstances.   There is  no material  before  

us  to  come  to  this  conclusion  that  the  undertaking given by the appellant was under  duress.   On  the  contrary  we  find  that  the  appellant  had given the  solemn undertaking  voluntarily. We, therefore, find no merit in the  appeal.”

44. The  Tribunal  in  paras  45-47  of  its  order  has  used  the  

expression “out of compulsion some of the developers entered into  

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Power Purchase Agreement with APTRANSCO accepting the terms  

and conditions set out in order dated 20th June, 2001”.  We are afraid  

that  there is  hardly any material  on record to  substantiate such a  

finding.  What was the compulsion and what were the facts which  

persuaded the Tribunal to take such a view are conspicuous by their  

very absence.  A compulsion leading to execution of a contract is a  

matter  entirely  based  upon  facts.   It  is  difficult  for  this  Court,  

originally,  to  infer  duress  or  compulsion  in  absence  of  specific  

pleadings and materials in that behalf.  It may also be noticed at the  

cost  of  repetition  that  the  order  dated  20th June,  2001 was never  

questioned by any of the parties to any favourable results.  Even in  

these  proceedings  there  is  no  challenge  to  the  said  order  which,  

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admittedly,  has  been  acted  upon  and  has  attained  finality.   The  

power  generators/Non-Conventional  Energy  developers  have  

executed the PPAs without any protest and, in fact,  did nothing to  

challenge such agreements  or  any part  thereof,  till  passing  of  the  

impugned order  of  2004.   There  were some proceedings,  without  

questioning  the  validity  and  effectiveness  of  the  order  dated  20th  

June, 2001, carried out by some of the generators before the Andhra  

Pradesh High Court.  Certain interim directions were passed in those  

proceedings,  as  already  noticed,  but  finally  all  proceedings  

culminated into dismissal of the Writ Petitions and/or reference back  

to  the  Regulatory  Commission  for  grant  of  a  hearing  as  per  the  

directions contained in the order of the High Court.

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45. Another  important  aspect  of  the  case  is  that  the  learned  

counsel  appearing  for  the respondents,  particularly,  in  Appeal  No.  

2926 of 2006 had stated that they are not arguing in support of the  

plea  of  estoppel  and  duress  as  decided  by  the  Tribunal  in  their  

favour.   They  had  mainly  concentrated  their  submissions  on  

jurisdiction of the Regulatory Commission with respect to withdrawal  

of  incentives and fixation of  tariff.   These are the contracts  which  

have been executed prior and after the issuance of the order dated  

20th June, 2001 and have been acted upon by the parties without any  

reservation. In view of the fact that no challenge was made to the  

order dated 20th June, 2001, execution of PPAs and the conduct of  

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the respondents over the long period and particularly, while keeping  

in mind the statutory provisions we are unable to sustain the plea of  

duress in favour of the respondents.

46. The main emphasis of the judgment of the Tribunal is that the  

Government  had  framed  the  policy  under  which,  incentives  were  

given and as such, the Regulatory Commission had no power and  

authority to  fix  tariffs  or  amend or  alter  the policy decision of  the  

State.  We have already held that in law and in face of the contract  

between the parties the Regulatory Commission is the Authority to fix  

the tariff  which includes within its  ambit  the purchase price of  the  

Non-conventional Energy under the policy of the State.  It  appears  

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that the Tribunal has taken a narrower view of the jurisdiction vested  

in  the  Regulatory  Commission  which  is  discharging  its  statutory  

functions under all the three Acts in accordance with law.  In terms of  

Section 12 of the Reform Act, 1998, which has been referred to by  

the Tribunal,  the power of the Government had been stated.   The  

power available to the Government to issue policy directions has two  

restrictions.   Firstly,  the  policy direction  has to  be on the  matters  

related  to  electricity  in  State  including  overall  planning  and  

coordination.  Secondly, all such policy directions have to be issued  

by the State Government in consonance with the object sought to be  

achieved by this  Act  and accordingly shall  not  adversely affect  or  

interfere  with  the  functions  and  powers  of  the  Regulatory  

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Commission  including,  but  not  limited  to,  determination  of  the  

structure of tariff for supply of electricity to the consumers.  Powers  

vested  in  the  Regulatory  Commission  to  frame  regulations  under  

Section  54  also  intend  that  regulations  are  to  be  framed  with  an  

object to ensure proper performance of its functions under the Act.  

In other words, both the State and the Regulatory Commission, are  

supposed to exercise their respective powers only for the purposes  

of furthering the cause of the Act.  The Commission discharging its  

statutory functions within the ambit of Sections 11, 12 and 26 of the  

Reform Act,  1998 as well  as Sections 61,  62 and 86(1)(b)  of  the  

Electricity  Act,  2003  renders  advisory  functions  to  the  State.   All  

these  provisions,  examined  and  analyzed  cumulatively,  do  not  

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support the approach adopted by the Tribunal that the functions of  

the  Regulatory  Commission  in  fixing  tariff/purchase  price  was  

contrary to or distinctive of the said policy.  This cannot be supported  

either on the basis of the statutory provisions of the various Acts as  

well as with reference to the various documents on record including  

the order dated 20th June, 2001 and the PPAs signed by the parties  

at different stages.  We are also unable to contribute to the view of  

the  Tribunal  that  the  Regulatory  Commission  has  acted  in  

contradiction or conflict with the State policy.  The State was certainly  

not intending to provide incentives and concessions with assurance  

of  buy-back  to  enable  the  Non-Conventional  Energy  

developers/generators  to sell  generated powers to third parties.  It  

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must be kept in mind that the policy of the Government of India as  

well  as  the  State  of  Andhra  Pradesh  was  for  encouraging  the  

developers/generators  of  Non-conventional  Energy  to  generate  

electricity for the benefit  of public  at large with buy back of power  

being one of the basic features of this policy.  Such parameters are  

obviously subject to change in larger public interest.  All these issues,  

in fact, loose much significance because of the fact that parties have,  

by and large, entered into the field of contract simpliciter and their  

rights are controlled by the contracts executed between them.  There  

is no challenge to these contracts and, therefore,  it may be hardly  

permissible  for  the Court  to go behind these contracts  and permit  

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questioning  of  the  statutory  jurisdiction  vested  in  the  Regulatory  

Commission.

47. In the case of BSES Ltd. v. Tata Power Co. Ltd. [(2004) 1 SCC  

195],  the  Court  clearly  held  that  after  creation  of  the  Regulatory  

Commissions  under  the  provisions  of  the  Electricity  Regulatory  

Commission  Act,  1998,  the  Commission  has  clear  power  and  

jurisdiction to fix tariff. The Court should not adopt an interpretation  

which  should  neither  be  strict  nor  narrower  so  as  to  oust  the  

jurisdiction of the Regulatory Commission, as it would defeat the very  

object  of  enacting  the  said  Act.  The  reliance  placed  by  the  

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respondents upon the judgment of this Court in the case of Andhra  

Pradesh Electricity Regulatory Commission v. R.V.K. Energy Private  

Limited [(2008) 17 SCC 769] is, again, of not much help to them.  In  

that case also, the Court had upheld the exercise of statutory power  

by the Regulatory Commission.  Of course, the Court held that the  

regulatory  power  u/s  11(1)(e)  of  the  Reform  Act,  1998  does  not  

ordinarily extend to prohibition or positive direction for entire supply to  

APTRANSCO  alone.   Such  prohibition  may  be  resorted  to  in  

exceptional situations.  It reiterated the principle that the Government  

policy  as  well  as  the  Regulatory  Commission  should  act  in  

consonance with the object of the Act.

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48. The  appellants  have  referred  and  relied  upon  the  policy  

directions and guidelines framed by the Central  Government while  

the respondents have relied upon these documents as well as the  

circulars issued by the State of Andhra Pradesh.  The respondents  

have raised the plea of estoppel against the Regulatory Commission  

on  the  basis  of  the  averment  that  the  State  had framed policies,  

which  the  Regulatory  Commission  instead  of  implementing,  has  

acted contrary thereto. There is no doubt that before the formation of  

the Regulatory Commission it was the State Electricity Board which  

was performing all the functions in relation to generation as well as  

distribution of electricity.  The Board was directly under the control of  

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the State and  the State, in exercise of its general executive powers,  

had  framed  policies  to  encourage  Non-conventional  Energy  

developers  and  producers  to  come into  the  field  of  generation  of  

electricity  and had  issued  the  Government  orders  which we have  

discussed  in  some  detail  above.   Strange  enough,  the  State  of  

Andhra Pradesh was neither impleaded as a party to the proceedings  

before the Regulatory Commission nor before the Tribunal.  In fact,  

the Tribunal has referred to various acts and deeds of the State and  

consequences thereof, but did not consider it appropriate to implead  

the State Government as a party to the proceedings.  We are of the  

considered view that presence of the State Government before the  

Tribunal  could  have  certainly  been  appropriate,  inasmuch  as  the  

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State  would  have  placed  before  the  Appellate  Authority  and  the  

Regulatory authorities, its views in regard to revision of incentives as  

well as the purchase price.  We are also constrained to observe that  

the State of Andhra Pradesh was a necessary, in any case, a proper  

party in these proceedings.   This itself  would be a ground for this  

Court to remit the matter to the Competent Authority, in addition to  

the other reasons recorded in this judgment.

49. In  the present  case,  the restriction with regard to  third  party  

sales was not only creation of a directive issued or approval granted  

by the Regulatory Commission, but was actually in furtherance to the  

contract  entered  into  between  the  parties.   Rights  and  liabilities  

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arising from a binding contract cannot be escaped on the basis of  

some presumptions or inferences in relation to the facts leading to  

the execution of the contract between the parties.  The jurisdiction of  

the Regulatory Commission, in the facts of the case, arises not only  

from  the  statutory  provisions  under  the  different  Acts  but  also  in  

terms of the contract executed between the parties which has binding  

force.  Lastly, but with great emphasis, it was argued on behalf of the  

respondents  that  enforcement  of  the  purchase  price  at  the  rate  

determined  by  the  Regulatory  Commission  along  with  complete  

prohibition  on  the  right  of  the  Non-conventional  Energy  

Generator/Developers  to  sell  generated  power  to  the  third  parties  

would compel them to shut down their projects.   The rates are so  

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unfair that it would result in extinguishment of the power generating  

units from the State of Andhra Pradesh on the one hand, while on the  

other,  it  is  bound  to  prejudicially  affect  the  larger  public  interest.  

According  to  the  respondents  they  have  invested  large  sums  of  

money in developing these generating units and it  will be unfair to  

compel their closure, particularly, when for all these years they have  

supplied electricity generated by them solely to APTRANSCO or its  

predecessors.   

50. We find some substance in this submission and are of the view  

that it is a matter of some concern, even for the State Government.  

All these projects, admittedly, were established in furtherance to the  

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scheme  and  the  guidelines  provided  by  the  Central  Government  

which,  in  turn,  were adopted  with  some modification  by the  State  

Government.   The  State  Electricity  Board  implemented  the  said  

scheme and initially  had permitted  sale  of  generated  electricity  to  

third  parties,  however,  subsequently  and  after  formation  of  the  

Regulatory Commission which, in turn, took over the functions of the  

State  Electricity  Board,  the  incentives  were  modified  and  certain  

restrictions  were placed.   The reasons  for  these  restrictions  have  

been stated in the affidavit filed on behalf of the appellants which, as  

already noticed by us, is not a matter to be examined by this Court in  

exercise of its extra-ordinary jurisdiction.  These matters, essentially,  

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must be examined by expert bodies particularly, when such bodies  

are constituted under the provisions of a special statute.

51. The  basic  policy  of  both  the  Central  as  well  as  the  State  

Government  was  to  encourage  private  sector  participation  in  

generation,  transmission  and  distribution  of  electricity  on  the  one  

hand  and  to  further  the  objective  of  distancing  the  regulatory  

responsibilities of the Regulatory Commission from the Government  

and of  harmonizing and rationalizing the provisions of  the existing  

laws relating to electricity in India, on the other hand.  The object and  

reasons of Electricity Act, 2003 as well as the Reform Act, 1998 are  

definite  indicators  of  such  legislative  intent.   The basic  objects  of  

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these enactments  were that  the said Regulatory Commission may  

permit  open  access  in  distribution  of  energy  as  well  as  to  

decentralize  management  of  power  distribution  through  different  

bodies.  The Reform Act, 1998 stated in its objects and reasons that  

the  set-up  of  power  sector  in  force,  at  that  time,  was  virtually  

integrated  and  functional  priorities  were  getting  distorted  due  to  

resource-crunch.   This  has  resulted  in  inadequate  investment  in  

transmission and distribution which has adversely affected the quality  

and reliability of supply.  The two corporations proposed thereunder  

were to be constituted to perform various functions and to ensure  

efficiency and social object of ensuring a fair deal to the customer.  

These  objects  and  reasons  clearly  postulated  the  need  for  

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introduction  of  private  sector  into  the  field  of  generation  and  

distribution  of  energy in  the State.   Efficiency in performance  and  

economic utilization of resources to ensure satisfactory supply to the  

public at large is the paramount concern of the State as well as the  

Regulatory Commission.  The policy decisions of these constituents  

are  to  be  in  conformity  with  the  object  of  the  Act.   Thus,  it  is  

necessary that  the Regulatory Commission,  in  view of  this  object,  

take practical  decisions which would help in ensuring existence of  

these units rather than their extinguishment as alleged.

52. In view of our above detailed discussion, we dispose of these  

appeals with the following order:

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(a) The order of the Tribunal dated 2nd June, 2006 is hereby set    

       aside.

(a) We  hold  that  the  Andhra  Pradesh  Electricity  Regulatory  

Commission has the jurisdiction to determine tariff which  

takes  within  its  ambit  the  ‘purchase  price’  for  

procurement  of  the  electricity  generated  by  the  Non-

conventional energy developers/ generators, in the facts  

and circumstances of these cases.

(b) We  hereby  remand  the  matters  to  the  Andhra  Pradesh  

Electricity Regulatory Commission with a direction that it  

shall  hear  the  Non-conventional  energy  generators  

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afresh  and  fix/  determine  the  tariff  for  purchase  of  

electricity in accordance with law, expeditiously.  

(c) It shall also re-examine that in addition to the above or in the  

alternative, whether it would be in the larger interest of  

the  public  and  the  State,  to  permit  sale  of  generated  

electricity to third parties, if otherwise feasible.  

(d) The Andhra Pradesh Electricity Regulatory Commission shall  

consider and pronounce upon all the objections that may  

be  raised  by  the  parties  appearing  before  it,  except  

objections in relation to its jurisdiction, plea of estoppel  

and  legitimate  expectancy  against  the  State  and/or  

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APTRANSCO  and  the  plea  in  regard  to  PPAs  being  

result of duress as these issues stand concluded by this  

judgment.

(e) We make it clear that the order dated 20th June, 2001 passed  

by  the  Andhra  Pradesh  Electricity  Regulatory  

Commission has attained finality and was not challenged  

in  any  proceedings  so  far.   This  judgment  shall  not,  

therefore, be in detriment to that order which will  operate  

independently and in accordance with law.

(f) We also hereby direct that State of Andhra Pradesh shall be  

added  as  a  party  respondent  in  the  proceedings  and  the  

Andhra  Pradesh  Electricity  Regulatory  Commission  shall  

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grant  hearing  to  the  State  during  pendency  of  proceeding  

before it.

 53.           In the facts and circumstances of the case parties are left  

to bear their own costs.

........................................J. [DR. B.S. CHAUHAN ]

........................................J.       [ SWATANTER KUMAR ]

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New Delhi July 8, 2010

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