Definition and Nature
Administrative discretion refers to the flexibility granted to administrative authorities in making decisions within the framework of the law. When such discretion is exercised in the context of determining rights and liabilities—especially where the authority is required to act judicially—it is termed a quasi-judicial decision. Quasi-judicial functions stand midway between administrative and judicial functions: they involve a discretionary element like administrative actions but require adherence to principles of natural justice and objective decision-making akin to judicial proceedings.
Key Features of Quasi-Judicial Decisions:
Judicial Control and Limits on Administrative Discretion
Indian courts exercise control over administrative discretion at two stages:
At the stage of exercise: Courts review whether discretion has been exercised properly and within legal bounds. They intervene if:
The authority has abdicated its power (e.g., acted under dictation).The authority has not exercised discretion properly (e.g., acted unreasonably, arbitrarily, or ignored relevant considerations).Parameters for Judicial Review:
Landmark Supreme Court Judgments
| Case Name | Citation | Principle Established |
|---|---|---|
| A.K. Kraipak v. Union of India | AIR 1970 SC 150 | The distinction between administrative and quasi-judicial powers is narrowing. Principles of natural justice apply to administrative decisions with civil consequences. The Court held the selection process invalid due to bias and lack of fair hearing. |
| Purtabpore Company Ltd. v. Cane Commissioner of Bihar | AIR 1970 SC 1896 | Discretion exercised under dictation of another authority is not a valid exercise of discretion; such acts are liable to be quashed. |
Haryana Finance Corporation v. Jagdamba Oil Mills | (2002) 3 SCC 496 | Quasi-judicial authorities must act fairly and adhere to the rule of law. |
| Nalin Kumar Bhatia v. Union of India | (2020) 4 SCC 78 | Judicial scrutiny is concerned with legality and validity, not the rank or position of the decision-maker. |
| Moons Technology Ltd. v. Union of India | (2019) 18 SCC 401 | Validity of an order must be judged by reasons stated in the order, not by subsequent justifications. |
| NSDL v. SEBI | (2017) 5 SCC 517 | For an administrative act to be quasi-judicial, there must be legal authority, the authority must determine rights, and there must be a duty to act judicially. |
Recent Supreme Court judgments continue to emphasize:
Conclusion
Administrative discretion in quasi-judicial decisions is essential for effective governance but is subject to significant judicial oversight. The Supreme Court has repeatedly held that such discretion must be exercised fairly, reasonably, and in accordance with the principles of natural justice. Courts remain vigilant to ensure that administrative authorities do not misuse their discretionary powers, safeguarding the rights of citizens against arbitrariness and abuse.
Here’s an easy-to-understand summary of "Administrative Discretion in Quasi-Judicial Decisions" with a mind map for quick revision.
1. Easy Summary for Exam
What is Administrative Discretion?
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Meaning: Power given to government officials to make decisions within legal limits.
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Example: Deciding who gets a license, or how to apply a rule in a specific case.
What are Quasi-Judicial Decisions?
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Meaning: Decisions by authorities that affect people’s rights, similar to a court, but not exactly a court.
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Features:
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Must follow natural justice (fair hearing, no bias).
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Must give reasons for decisions.
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Cannot act arbitrarily (randomly or unfairly).
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Judicial Control (How Courts Check Discretion)
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At the time of making the law: Courts check if the law giving discretion is clear and not too broad.
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At the time of using the power: Courts check if the official used the power fairly, reasonably, and by following the rules.
Grounds for Challenging Discretion
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Ultra Vires: Beyond legal power.
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Abuse of Power: Used for wrong reasons or unfairly.
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No Application of Mind: Not thinking independently.
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Violation of Natural Justice: Not giving a fair hearing or being biased.
2. Landmark Supreme Court Judgments (Easy to Remember)
| Case Name | Key Point |
|---|---|
| A.K. Kraipak v. Union of India (1969) | Natural justice applies to administrative actions; must act fairly. |
| Purtabpore Company Ltd. v. Cane Commissioner (1970) | Can’t act on someone else’s instructions (no dictation). |
| Haryana Finance Corp. v. Jagdamba Oil Mills (2002) | Must act fairly and reasonably. |
| ADM Jabalpur v. Shivkant Shukla (1976) | Judicial review prevents arbitrary use of power. |
Administrative Discretion in Quasi-Judicial Decisions │ ├── What is it? │ ├─ Power to decide within legal limits │ └─ Applies to rights & duties │ ├── Features of Quasi-Judicial Decisions │ ├─ Duty to act fairly (Natural Justice) │ ├─ Give reasons │ └─ No arbitrariness │ ├── Judicial Control │ ├─ At law-making (clear, not too broad) │ └─ At exercise (fair, reasonable, follow rules) │ ├── Grounds for Challenge │ ├─ Ultra vires (beyond power) │ ├─ Abuse of power │ ├─ No application of mind │ └─ Violation of natural justice │ └── Landmark Cases ├─ A.K. Kraipak: Fairness & natural justice ├─ Purtabpore: No dictation ├─ Haryana Finance: Reasonableness └─ ADM Jabalpur: Judicial review
Tips to Memorize
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Case Shortcuts:
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Kraipak = Fairness
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Purtabpore = No Dictation
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Jagdamba = Reasonable
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ADM Jabalpur = Review
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Quick Revision:
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Discretion ≠ absolute power
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Must follow natural justice
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Courts can check misuse
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Remember 4 landmark cases
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