VIRUDHUNAGAR STEEL ROLLING MILLS LIMITED vs THE GOVERNMENT OF MADRAS

The Supreme Court held that the petitioner's writ petition under Article 32 was barred by res judicata as the petitioner did not appeal from the Division Bench's speaking order dismissing the earlier petition. The Court clarified that a speaking order, even if made without notice to the other side, disposes of the matter on merits and thus bars subsequent petitions on the same facts. The Court also upheld the validity of Section 12 of the Madras Electricity (Taxation on Consumption) Act, 1962, stating it was not violative of Article 14 of the Constitution.