A.K. Kraipak v. Union of India
Rule established
Natural justice applies to administrative (not only quasi-judicial) functions; duty to act fairly applies wherever rights are affected; rule against bias in selection processes
Facts
- Selection Board was constituted to select officers for Indian Forest Service
- One member of the Selection Board (Naqishbund) was himself a candidate for selection
- Kraipak (not selected) challenged the process alleging bias
- Government argued: selection is administrative (not quasi-judicial), so natural justice does not apply
- Selection Board was advisory; final selection was by government
Issues
- Whether principles of natural justice apply to administrative (as opposed to quasi-judicial) proceedings?
- Whether a member of selection board who is simultaneously a candidate creates bias vitiating the process?
Held
- The dividing line between quasi-judicial and administrative functions is thin and increasingly irrelevant
- Natural justice (specifically rule against bias) applies to administrative decisions that affect rights
- Where determination of comparative fitness of candidates affects their career rights, duty to act fairly applies
- Naqishbund being both selector and candidate created reasonable apprehension of bias: structural conflict of interest
- Entire selection vitiated regardless of whether Naqishbund actually influenced other members
Ratio Decidendi
The distinction between quasi-judicial and administrative functions should not determine whether natural justice applies. The real test is whether the decision affects the rights of a person. If it does, the duty to act fairly requires that the decision-maker be free from bias and the process be fair, regardless of how the function is classified. Bias in a selection committee vitiates the entire selection even if the biased member did not directly benefit.
How to use it in an exam
- Deploy in questions on classification of functions, natural justice, bias, duty to act fairly.
- Key line: "The dividing line between an administrative power and a quasi-judicial power is quite thin and is being gradually obliterated. Under our Constitution the duty to act fairly is ingrained in every administrative action."
- Part B (15 marks): Use as turning-point case; before Kraipak, natural justice was confined to quasi-judicial functions. After Kraipak, it extends to all administrative decisions affecting rights.
Source
Source: Massey, Administrative Law; Sathe, Administrative Law; Wade, Administrative Law
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.