BIHAR STATE ELECTRICITY BOARD vs HOTEL SATKAR (PVT.) LTD., PATNA

The Supreme Court upheld the Patna High Court's ruling that under Section 24(1) of the Indian Electricity Act, 1910, a licensee cannot issue a notice of disconnection when a bona fide dispute exists between the licensee and the consumer regarding the billing. The Court affirmed that in the absence of a formal agreement, the consumer should be charged based on actual consumption rather than contract demand. The High Court's mandamus preventing disconnection until the dispute is resolved was thus validated.