Unreasonableness as a ground for judicial review
Unreasonableness as a Ground for Judicial Review
What is Judicial Review?
Judicial review is the power of courts to examine the actions or decisions of administrative authorities and declare them invalid if they violate legal principles, including constitutional provisions.
What Does "Unreasonableness" Mean in Administrative Law?
Unreasonableness is one of the key grounds on which courts can review and quash administrative decisions.
It means that the decision is so irrational, arbitrary, or perverse that no reasonable authority could have made it.
The standard is not simply that the court disagrees with the decision, but that the decision is beyond the range of reasonable choices.
Courts use the principle of unreasonableness to check abuse of discretionary power.
Origin in India
The concept of unreasonableness as a ground of review has been adopted from common law principles, particularly from UK jurisprudence.
Article 14 (Right to Equality) of the Indian Constitution implicitly prohibits arbitrary and unreasonable state actions.
How is Unreasonableness Assessed?
Courts look at:
Whether the authority considered relevant facts.
Whether irrelevant considerations were taken into account.
Whether the decision is arbitrary, capricious, or made in bad faith.
Whether the decision defies logic or accepted norms.
Important Case Laws on Unreasonableness as Ground of Judicial Review
1. Associated Provincial Picture Houses Ltd. vs. Wednesbury Corporation (1948) (English Case)
Though not Indian, this case is foundational in the concept of unreasonableness:
The Court held that a decision would be unreasonable if it is so outrageous in its defiance of logic or accepted moral standards that no sensible person who applied their mind to the question could have arrived at it.
This “Wednesbury unreasonableness” standard influenced Indian jurisprudence heavily.
2. Maneka Gandhi vs. Union of India (1978)
Context: Government impounded Maneka Gandhi’s passport without fair hearing.
Significance:
The Supreme Court broadened the scope of Article 21 to include the right to fair procedure.
Held that administrative action that is arbitrary or unreasonable violates fundamental rights.
The Court emphasized that laws and executive actions must be just, fair, and reasonable.
Impact: Established unreasonableness as a ground for judicial review linked to fundamental rights.
3. State of Haryana vs. Chandra Mani (1979)
Context: Government passed an order cancelling the appointment of an individual.
Significance:
The Court held that administrative decisions must be reasonable and based on relevant material.
It struck down the cancellation for being arbitrary and lacking any justifiable basis.
Highlighted that administrative decisions cannot be whimsical or capricious.
Impact: Reinforced that unreasonableness includes arbitrariness and lack of relevant consideration.
4. Delhi Transport Corporation vs. D.T.C. Mazdoor Congress (1991)
Context: Challenge to disciplinary action taken against employees.
Significance:
The Supreme Court held that administrative actions must pass the test of reasonableness under Article 14.
Actions that are disproportionate, discriminatory, or arbitrary are liable to be quashed.
The Court emphasized fairness and reason in administrative decisions affecting service conditions.
Impact: Developed the concept of proportionality as part of reasonableness.
5. Gujarat University vs. Krishna Gopal Patel (1992)
Context: University decision denying affiliation to a college.
Significance:
The Court held that the university’s decision was unreasonable and arbitrary as it was made without applying proper mind or relevant criteria.
The decision was quashed for being outside the ambit of reasonableness and fairness.
Impact: Showed how reasonableness applies in administrative discretion affecting rights and privileges.
Summary
Unreasonableness is a vital and powerful ground for judicial review in Indian administrative law.
It protects citizens from arbitrary, capricious, and irrational decisions by administrative authorities.
Courts apply tests of logical consistency, relevant consideration, and proportionality.
Landmark cases like Maneka Gandhi and Delhi Transport Corporation emphasize fairness and non-arbitrariness as constitutional mandates.
The principle ensures that administrative discretion is exercised within legal and rational boundaries.
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