Question

“The rules of natural justice were not confined to the narrow precincts of the prevailing definition of quasi-judicial functions.” This principle was laid down in which case?

• A. A.K. Kraipak v. Union of India AIR 1970 SC 150
• B. Ridge v. Baldwin (1964) A.C. 40
• C. Maradana Mosque Trustees v. Mahmud (1967) (1) A.C. 13
• D. Conway v. Rimmer (1968) A.C. 910

Hint:

"Kraipak" = Breaking the wall! It broke the wall between quasi-judicial and administrative functions, making "Fairness" the universal requirement for all state actions.

Answer 1

The Correct Option is A

Before this case, Indian courts largely tied natural justice to bodies performing quasi-judicial functions, so the question is really asking which judgment broke that boundary.

1. Ridge v. Baldwin: An important English precedent reviving the right to a hearing before dismissal, but its specific contribution is about procedural fairness in office removal, not the Indian doctrinal expansion described in the quote.
2. A.K. Kraipak v. Union of India: The Supreme Court here expressly said that the distinction between quasi-judicial and purely administrative functions was thinning, and that fairness requirements should extend to administrative action too. This is precisely the "not confined to the narrow precincts" language traceable to this decision.
3. Maradana Mosque Trustees v. Mahmud: A Privy Council decision on natural justice in a specific dismissal context, distinct from the broader doctrinal expansion the quote describes.
4. Conway v. Rimmer: This case is about Crown privilege and evidence disclosure, unrelated to natural justice's scope over administrative functions.

The specific expansion of natural justice beyond quasi-judicial functions is a doctrine most closely tied to one particular Indian Supreme Court ruling.

\[ \boxed{\text{A.K. Kraipak v. Union of India AIR 1970 SC 150}} \]

Answer 2

Since three of these four cases are foreign precedents and one is Indian, it is worth checking whether the quoted principle, phrased in the language typically used by Indian courts, points to the Indian case among them.

1. Option (A) - A.K. Kraipak: This is the Indian Supreme Court decision that is widely cited for exactly this proposition, that natural justice is not limited to the narrow precincts of quasi-judicial functions, making it the direct source of the quoted language.
2. Option (B) - Ridge v. Baldwin: An English House of Lords case focused on a different aspect of natural justice, the right to be heard before removal from an office, rather than this specific formulation.
3. Option (C) - Maradana Mosque Trustees v. Mahmud: A Privy Council case on natural justice in a school-committee dismissal context, again distinct from the quoted doctrinal expansion.
4. Option (D) - Conway v. Rimmer: An English case on public interest immunity for documents, entirely unconnected to natural justice's scope.

The wording and doctrinal content of the quote track the Indian Supreme Court's reasoning in this particular case.

Hence, the correct answer is A.K. Kraipak v. Union of India AIR 1970 SC 150.