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In which of the following cases has the Supreme Court held that "Administration of Public Authority cannot be invalidated merely for not recording rea
Question

In which of the following cases has the Supreme Court held that "Administration of Public Authority cannot be invalidated merely for not recording reasons when it had no duty to do so?"

A.

National Highway Authority of India v. Madhukar Kumar (2022)

B.

Municipal Council Neemuch v. Mahadeo Real Estate (2019)

C.

Tata Cellular v. Union of India (1994)

D.

Vijay Narayan Sharma v. State of Rajasthan (2022)

Correct option is A


The Supreme Court, in National Highway Authority of India v. Madhukar Kumar (2022), ruled that the administration of public authority cannot be invalidated merely for not recording reasons when there is no legal obligation to do so.

(b) Municipal Council Neemuch v. Mahadeo Real Estate (2019):
This case primarily dealt with unauthorized occupation and public property, and the right to fair compensation under Article 300A of the Constitution. It focused on procedural due process and reasonable compensation, not on the obligation to record reasons in administrative actions.

(c) Tata Cellular v. Union of India (1994):
A landmark case in administrative law and judicial review, it laid down the principles for judicial review of administrative decisions, especially in the realm of tendering and government contracts. While it emphasized transparency, fairness, and reasonableness, it did not rule that failure to record reasons voids all administrative acts unless there is a duty to provide reasons.

(d) Vijay Narayan Sharma v. State of Rajasthan (2022):
This case dealt with appointment and selection process in public employment and discussed issues of arbitrariness and mala fides, not specifically with the principle regarding non-recording of reasons by a public authority.

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