The case involved a challenge to the constitutional validity of Section 10(3) of the Uttar Pradesh Motor Vehicles Taxation Act, 1997. This section imposed a penalty of ten times the ... due tax on transport vehicles found plying in Uttar Pradesh without payment of the requisite tax. Sukhpal Singh Bal, the owner of a tanker with a national permit, contested the imposition of this penalty, alleging that it was harsh, unreasonable, and discriminatory.