The principle of reasonableness in administrative decision-making
📘 The Principle of Reasonableness in Administrative Decision-Making
🔹 Introduction
In administrative law, reasonableness refers to the idea that all administrative actions and decisions by public authorities must be:
Rational
Just
Fair
Not arbitrary or capricious
It is a key principle used by courts to review executive and administrative actions, ensuring that such decisions comply with the Constitution, particularly Articles 14 (equality) and 21 (life and liberty).
🔹 Legal Basis in Indian Constitution
| Article | Relevance |
|---|---|
| Article 14 | Forbids arbitrariness; mandates equality before law |
| Article 21 | Due process and fairness in state action |
| Article 226 & 32 | Allow judicial review of unreasonable administrative actions |
🔹 Dimensions of Reasonableness
Substantive Reasonableness: The content or outcome of the decision must be fair.
Procedural Reasonableness: The process followed must be fair and consistent with natural justice.
Wednesbury Reasonableness (from UK law): A decision is unreasonable if:
It is so absurd that no sensible person would make it.
It defies logic or accepted moral standards.
🏛️ Key Indian Case Laws – Explained in Detail
Let’s now analyze more than five important cases that have established and elaborated the principle of reasonableness in administrative law in India.
🔸 1. Maneka Gandhi v. Union of India (1978)
📌 Facts:
Maneka Gandhi’s passport was impounded by the government without giving her a reason or hearing.
⚖️ Judgment:
Supreme Court held that procedure affecting life and liberty must be "just, fair, and reasonable".
Expanded the interpretation of Article 21.
Reasonableness became a constitutional requirement.
🧾 Significance:
Administrative action affecting fundamental rights must satisfy both procedural and substantive reasonableness.
🔸 2. A.K. Kraipak v. Union of India (1970)
📌 Facts:
A selection board member was also a candidate for the same post.
⚖️ Judgment:
The selection process was held unreasonable and biased.
The Court stated that administrative actions must follow principles of natural justice.
🧾 Significance:
Blurred the distinction between administrative and quasi-judicial functions.
Fairness and reasonableness are essential even in administrative decisions.
🔸 3. E.P. Royappa v. State of Tamil Nadu (1974)
📌 Facts:
Challenge to transfer of a civil servant allegedly made arbitrarily and unfairly.
⚖️ Judgment:
Supreme Court held that arbitrariness is the antithesis of reasonableness and a violation of Article 14.
Even non-legislative state actions must be reasonable and non-arbitrary.
🧾 Significance:
Established that all state action must be tested for reasonableness, not just legislative or judicial.
🔸 4. R.D. Shetty v. International Airport Authority (1979)
📌 Facts:
A tender was rejected arbitrarily despite the applicant meeting eligibility conditions.
⚖️ Judgment:
Supreme Court ruled that public bodies must act fairly, especially in awarding contracts.
Even in commercial matters, reasonableness and fairness are mandatory.
🧾 Significance:
Introduced reasonableness and fairness in administrative discretion, especially in public contracts.
🔸 5. State of Maharashtra v. Lok Shikshan Sanstha (1977)
📌 Facts:
Recognition of a school was withdrawn without giving proper reasons or hearing.
⚖️ Judgment:
Held the action was arbitrary and unreasonable, violating Article 14.
The authority acted in violation of natural justice and proportionality.
🧾 Significance:
Reinforced that reasoned decisions are necessary.
Unreasoned administrative decisions are liable to be quashed.
🔸 6. Kranti Associates v. Masood Ahmed Khan (2010)
📌 Facts:
A quasi-judicial authority passed an order without giving reasons.
⚖️ Judgment:
Supreme Court held that reasoned decisions are an essential part of natural justice.
Speaking orders (orders with reasons) are required to ensure transparency and accountability.
🧾 Significance:
Lack of reasons in an administrative order makes it arbitrary and unreasonable.
🔸 7. Om Kumar v. Union of India (2001)
📌 Facts:
Government’s decision affecting service conditions was challenged for being arbitrary.
⚖️ Judgment:
Court applied the Wednesbury unreasonableness test and said that a decision is unreasonable if it shocks the conscience or is illogical.
🧾 Significance:
Recognized proportionality and Wednesbury principles in Indian administrative law.
📊 Summary Table
| Case Name | Key Principle on Reasonableness |
|---|---|
| Maneka Gandhi (1978) | Reasonableness is required in both procedure and substance |
| A.K. Kraipak (1970) | Administrative decisions must follow natural justice |
| E.P. Royappa (1974) | Arbitrariness is the opposite of reasonableness |
| R.D. Shetty (1979) | Discretion must be exercised reasonably |
| Maharashtra v. Lok Shikshan (1977) | Unreasoned decisions violate Article 14 |
| Kranti Associates (2010) | Speaking orders are essential for fairness |
| Om Kumar (2001) | Wednesbury test and proportionality adopted |
🔍 Key Principles Derived from Case Law
No Arbitrariness: Any arbitrary administrative action is unreasonable and unconstitutional.
Duty to Give Reasons: All administrative authorities must give reasoned decisions.
Fairness in Procedure: Natural justice and fair hearing are inseparable from reasonableness.
Proportionality: The action taken must be proportionate to the objective.
Wednesbury Unreasonableness: Decisions must not be so irrational that no reasonable person would take them.
📌 Conclusion
Reasonableness is a cornerstone of administrative justice in India.
It ensures that state power is exercised fairly, rationally, and lawfully.
Through judicial review, courts safeguard against arbitrariness, uphold natural justice, and enforce the constitutional mandate of equality and fairness.
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