Judicial review of administrative adjudication
⚖️ Judicial Review of Administrative Adjudication
✅ What is Administrative Adjudication?
Administrative adjudication refers to the process where administrative agencies or authorities exercise quasi-judicial functions—deciding disputes, imposing penalties, or regulating rights—outside the formal courts.
These bodies have power to adjudicate under statutes but are not courts per se.
✅ Why is Judicial Review of Administrative Adjudication Necessary?
To ensure fairness, legality, and reasonableness in administrative decisions.
To protect fundamental rights and legal rights of individuals.
To check arbitrariness, bias, and abuse of power.
To maintain rule of law and constitutional governance.
✅ Scope of Judicial Review
Courts generally review administrative adjudication on the following grounds:
| Ground | Explanation |
|---|---|
| Jurisdictional error | Whether the authority acted beyond its jurisdiction or powers. |
| Violation of principles of natural justice (PNJ) | Right to fair hearing, unbiased decision-making. |
| Error of law | Misinterpretation or non-application of law. |
| Factual error (limited scope) | Whether the decision is based on some evidence; courts don’t re-appreciate facts. |
| Reasonableness and proportionality | Decisions must not be arbitrary or oppressive. |
| Procedural irregularity | Failure to follow statutory procedures. |
🧑⚖️ Important Cases on Judicial Review of Administrative Adjudication
1. A.K. Kraipak v. Union of India (1969) 2 SCC 262
Facts:
The Central Government appointed a majority of members on the Selection Committee, including members with potential conflict of interest.
Held:
The Court held that procedural fairness is mandatory, even in administrative adjudication.
Bias or interest disqualifies decision-makers.
Administrative adjudication is subject to principles of natural justice.
Violation of PNJ can render decisions void.
Significance:
This is a landmark ruling that extends natural justice to administrative tribunals and quasi-judicial bodies.
2. Maneka Gandhi v. Union of India (1978) 1 SCC 248
Facts:
Maneka Gandhi’s passport was impounded without giving her an opportunity to be heard.
Held:
The Court broadened due process under Article 21 (right to life and personal liberty).
Any administrative action affecting rights must be fair, just, and reasonable.
Procedural safeguards must be followed in administrative adjudication.
Significance:
It established the doctrine of procedural fairness and reasonableness as mandatory in administrative decisions.
3. E.P. Royappa v. State of Tamil Nadu (1974) 4 SCC 3
Facts:
An IAS officer was dismissed arbitrarily.
Held:
The Court held arbitrariness violates the constitutional guarantee of equality.
Administrative adjudication must be free from arbitrariness, mala fide, or unfairness.
Significance:
Introduced the principle that administrative decisions must be reasonable and non-arbitrary.
4. Union of India v. Tulsiram Patel (1985) 3 SCC 398
Facts:
The rules of natural justice were questioned in the context of disciplinary proceedings against government servants.
Held:
Administrative adjudicators are bound by the rules of natural justice, including the right to be heard.
Failure to follow such rules makes the decision liable to be quashed.
Significance:
Reinforced the applicability of PNJ in administrative adjudication.
5. Subramanian Swamy v. Directorate of Enforcement (2014) 8 SCC 682
Facts:
Challenged the Enforcement Directorate’s order freezing assets without giving an opportunity to be heard.
Held:
The Court reiterated that administrative adjudication cannot deny fair hearing.
Even in economic offenses, principles of natural justice must be followed.
Significance:
Confirmed the universality of natural justice irrespective of the subject matter.
6. Siddharam Satlingappa Mhetre v. State of Maharashtra (2011) 1 SCC 694
Facts:
The validity of administrative detention under preventive detention laws was challenged.
Held:
Courts must conduct thorough scrutiny of evidence and procedure in administrative adjudications affecting liberty.
Mere compliance with procedural forms is insufficient; substance must be fair.
Significance:
Established that courts have wide powers of review in administrative decisions affecting fundamental rights.
7. Collector, Land Acquisition v. Mst. Katiji (1987) 2 SCC 590
Facts:
Land acquisition notice was issued without prior inquiry.
Held:
Court ruled that administrative actions requiring adjudication must comply with natural justice and fair procedure.
Any failure to do so renders the action invalid.
Significance:
Emphasized that even administrative decisions with legislative backing need procedural fairness.
8. LIC v. Consumer Education and Research Centre (1995) 5 SCC 482
Facts:
Decision of LIC on premium policies and agents’ commissions were challenged.
Held:
Courts must intervene if administrative decisions are arbitrary, unreasonable, or violate fundamental rights.
Judicial review extends to reasonableness of administrative orders.
Significance:
Expanded scope of review to include substantive fairness, not just procedural compliance.
📌 Summary Table: Grounds & Cases of Judicial Review
| Ground for Review | Case Example(s) | Key Principle |
|---|---|---|
| Violation of Natural Justice | A.K. Kraipak, Union of India v. Tulsiram Patel | Right to fair hearing and unbiased decision-maker |
| Arbitrariness / Unreasonableness | E.P. Royappa, LIC v. CERC | No administrative decision should be arbitrary |
| Jurisdictional Error | Katiji case | Decisions beyond authority are invalid |
| Violation of Fundamental Rights | Maneka Gandhi, Siddharam Mhetre | Procedural and substantive fairness mandatory |
| Procedural Irregularity | Collector, Land Acquisition v. Katiji | Compliance with statutory procedure necessary |
✅ Conclusion
Judicial review of administrative adjudication ensures that administrative bodies do not become instruments of unfairness or tyranny. The courts protect individuals from:
Excessive or unauthorized use of power
Lack of fair hearing
Arbitrary or unreasonable decisions
The judiciary thus acts as a guardian of rule of law and fairness, ensuring administrative adjudication conforms with constitutional and legal standards.
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