Supreme Court Upholds Rule Against Bias: Strengthening Natural Justice in Administrative Law
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The Supreme Court recently invalidated an administrative decision where the adjudicator acted as the complainant, reinforcing the principle of 'Nemo Judex in Causa Sua'. This ruling emphasizes that impartiality is a non-negotiable pillar of constitutional governance and fair play in quasi-judicial functions.
The Supreme Court of India has recently delivered a landmark judgment reinforcing the foundational principle of natural justice: Nemo Judex in Causa Sua (no one should be a judge in their own cause). The Court set aside an administrative decision on the grounds that the adjudicating officer also functioned as the complainant in the same matter. This ruling serves as a critical reminder that the 'rule against bias' is not merely a procedural formality but an essential component of constitutional governance.
The core of the dispute centered on a clear conflict of interest. In administrative law, quasi-judicial functions require a high degree of impartiality. When an individual who initiates a complaint also sits in judgment over it, the process is inherently tainted by 'personal bias.' The Supreme Court observed that such a practice violates the basic tenets of fair play and erodes public confidence in administrative institutions. The Court reiterated the famous legal aphorism that 'justice must not only be done but must also be seen to be done.'
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