The requirement to give reasons in administrative decisions which affect rights and liabilities has been held to be mandatory by the Supreme Court in .........

Question

“The question can also be considered from another point of view. Supposing the police send a report viz. a charge-sheet, under Section 170 of the Code. As we have already pointed out, the Magistrate is not bound to accept that report, when he considers the matter judicially. But can he differ from the police and call upon them to submit a final report, under Section 169? In our opinion, the Magistrate has no such power. If he has no such power, in law, it also follows that the Magistrate has no power to direct the police to submit a charge-sheet, when the police have submitted a final report that no case is made out for sending the accused for trial. The functions of the Magistracy and the police, are entirely different, and though, in the circumstances mentioned earlier, the Magistrate may or may not accept the report, and take suitable action, according to law, he cannot certainly infringe upon the jurisdiction of the police, by compelling them to change their opinion, so as to accord with his view. Therefore, to conclude, there is no power, expressly or impliedly conferred, under the Code, on a Magistrate to call upon the police to submit a charge-sheet, when they have sent a report under Section 169 of the Code, that there is no case made out for sending up an accused for trial.”
[Extracted from Abhinandan Jha v. Dinesh Mishra, (1967) 3 SCR 668, para 19-20].

Answer 1

This is a direct-recall question about which case fixed the duty to record reasons as mandatory, so the fastest way to answer it is to sort the four cases by the legal doctrine each one is actually remembered for.

S.N. Mukherjee v/s Union of India: Remembered specifically for holding that an administrative or quasi-judicial body must record reasons for its order, describing this duty as a facet of natural justice that checks arbitrariness and enables review. This matches the question exactly.
State of Orissa v/s Dr. Binapani Dei: Remembered for the principle that even administrative orders civil consequences must follow a fair hearing, i.e. audi alteram partem, not for the reasons requirement.
State of Maharashtra v/s Jalgaon Municipal Council: Concerns the scope of a municipal authority's statutory powers, not the reasons requirement.
Motilal Padampat Sugar Mills Co. Ltd. v/s State of U.P: The defining case for promissory estoppel against government bodies, unrelated to recording reasons.

Since only the first case is tied to the specific rule that reasons must be recorded for decisions affecting rights and liabilities, the correct answer is S.N. Mukherjee v/s Union of India.

Answer 2

Another way to reach the answer is to think about why the duty to give reasons exists at all, and then check which case actually rests its ruling on that rationale.

S.N. Mukherjee v/s Union of India: The rationale given here is that a reasoned order restrains arbitrary use of power, satisfies the party against whom it is made, and equips a reviewing court or authority to test the correctness of the decision. Since the question is framed around exactly this rationale, and this case is where the Supreme Court tied the giving of reasons to these purposes and made it mandatory, it fits precisely.
State of Orissa v/s Dr. Binapani Dei: The rationale in this case is different, it protects a person from having civil consequences imposed without first being heard, which is a pre-decisional safeguard rather than a post-decisional reasoning requirement.
State of Maharashtra v/s Jalgaon Municipal Council: This case turns on the statutory authority of a municipal body and does not build any rule around the necessity of recorded reasons.
Motilal Padampat Sugar Mills Co. Ltd. v/s State of U.P: The rationale here concerns holding government to its representations under equity, entirely separate from the natural-justice rationale for recording reasons.

Matching the rationale in the question to the actual holding of each case confirms that the correct answer is S.N. Mukherjee v/s Union of India.

Answer 3

Another way to reach the answer is to think about why the duty to give reasons exists at all, and then check which case actually rests its ruling on that rationale.

S.N. Mukherjee v/s Union of India: The rationale given here is that a reasoned order restrains arbitrary use of power, satisfies the party against whom it is made, and equips a reviewing court or authority to test the correctness of the decision. Since the question is framed around exactly this rationale, and this case is where the Supreme Court tied the giving of reasons to these purposes and made it mandatory, it fits precisely.
State of Orissa v/s Dr. Binapani Dei: The rationale in this case is different, it protects a person from having civil consequences imposed without first being heard, which is a pre-decisional safeguard rather than a post-decisional reasoning requirement.
State of Maharashtra v/s Jalgaon Municipal Council: This case turns on the statutory authority of a municipal body and does not build any rule around the necessity of recorded reasons.
Motilal Padampat Sugar Mills Co. Ltd. v/s State of U.P: The rationale here concerns holding government to its representations under equity, entirely separate from the natural-justice rationale for recording reasons.

Matching the rationale in the question to the actual holding of each case confirms that the correct answer is S.N. Mukherjee v/s Union of India.

The requirement to give reasons in administrative decisions which affect rights and liabilities has been held to be mandatory by the Supreme Court in .........

Show Hint

The Correct Option is A

Approach Solution - 1

Approach Solution -2

Top Questions on Administrative Law

Questions Asked in AIBE exam