PVR Inox Limited vs State of Chhattisgarh: Writ Petition Dismissed as Infructuous After State Declines Approval to Show Tax Hike

Overview of the Case

Court: Chhattisgarh High Court
Case: Pvr Inox Limited Vs State of Chhattisgarh
**Writ Petition No.😗* WPC No. 4498 of 2026
Date of Order: 10/09/2026

The Chhattisgarh High Court disposed of a writ petition filed by Pvr Inox Limited, finding that the core dispute had been effectively rendered moot by a subsequent executive decision. The petition, which arose from a municipal resolution proposing a sharp increase in cinema show tax, was dismissed as infructuous once it emerged that the State Government had withheld its approval to the very resolution being challenged.

Background: The Disputed Municipal Resolution

The controversy originated from Resolution (Sankalp Patra) No. 13 dated 10.04.2026, passed by the Mayor-in-Council of the Municipal Corporation, Raipur. Through this resolution, the municipal body proposed to revise the rate of 'Pradarshan Shulk' (Show Tax) applicable to cinema theatres operating within shopping malls — raising the levy from ₹200 per show per screen to ₹600 per show per screen, representing a threefold increase.

Following the passage of this resolution, a Demand Notice dated 24.04.2026 was issued to give effect to the proposed enhanced levy. It was this resolution and the consequential demand notice that formed the basis of the writ petition filed by Pvr Inox Limited before the Chhattisgarh High Court under Article 226 of the Constitution of India.

Grounds Raised by the Petitioner

The assessee — Pvr Inox Limited — raised several objections to the impugned resolution. The principal contentions advanced on its behalf were as follows:

  • The enhancement of 'Pradarshan Shulk' was arbitrary and excessive in nature.
  • The proposed increase was contrary to the provisions of the Chhattisgarh Municipal Corporation Act, 1956 and the broader constitutional framework that governs the imposition of municipal taxes.
  • Crucially, the petitioner argued that the resolution could not have been given effect to or acted upon without first obtaining the requisite sanction or approval of the State Government.

This last argument — relating to the necessity of prior State Government approval before such a resolution could be enforced — proved to be the central factor in the ultimate resolution of the dispute, albeit not on account of any judicial determination on the merits.