Abstract

Administrative law is an important safeguard against the arbitrary exercise of power by administrative authorities. Judicial interpretation and application of the doctrine has led to development of the doctrine which is featured as an essential pillar of administrative jurisprudence in almost all democratic setup around the world more particularly in India.

From regulatory decisions that affect industries to the delivery of services, through to policy implementation, citizen’s lives are affected by administrative actions on a daily basis. When exercising these powers, the doctrine of reasonableness guarantees these actions are carrying out in a manner that is just, sensible, and legal. It needs administrative decisions to be premised on relevant considerations, be proportionate with respect to their aims, and show a rational relationship between the facts

This paper examines the theoretical underpinnings behind the doctrine, how it has developed over time and its present usefulness within Indian jurisprudence. It identifies landmark cases that have tested and fine-tuned the doctrine, including transformative Supreme Court decisions which placed reasonableness at the heart of administrative review. The doctrine has been influential in cases where courts have invalidated arbitrary administrative actions, but its application also seeks to find a balance between judicial intervention and respect for the expertise and discretion of administrative bodies.

This paper questions the ability of the doctrine to resolve practical issues surrounding administrative governance, such as challenges to procedural fairness, substantive reasonableness, and changing norms of judicial review.

Through extensive analysis of constitutional provisions, statutory frameworks, judicial precedents, and scholarly literature, this research contributes to the discourse on administrative accountability and the role of judicial review in maintaining the delicate balance between administrative efficiency and protection against arbitrary power. By providing a comprehensive examination of the doctrine of reasonableness, this study aims to enhance understanding of this vital legal principle and its role in fostering a fair, transparent, and accountable administrative system.

INTRODUCTION

The principle of reasonableness is at the centre of the administrative law which, on the one hand, serves as a necessary restriction on the administrative authority’s discretion and, on the other hand, acts as a safeguard against the arbitrary execution of power. In democratic governance, executive and other authorities are often the ones who have the most power to make decisions that have an immediate effect on citizen’s rights and interests and their daily lives. The reasonableness of the authorities actions is represented in the fact that those who possess the decision-making responsibility in modern societies do so rationally, independently, and in compliance with the law.

Administrative law in India has developed significantly since the time of independence mainly through the judiciary and their role of laying down guiding principles for the regulation of administrative actions. It was the recognition of the absolute necessity to not only look for the legal validity but also for the rational and fair reasons for their administrative decisions that gave rise to the doctrine of reasonableness. This doctrine finds its origin in the constitutional ideals of equality, fairness, and the rule of law that are enshrined in a number of the fundamental rights including the Articles 14, 19, and 21 of the Indian Constitution.

The behaviour of reasonableness in administrative law invents a lot of aspects such as procedural reasonableness which involves the fairness of the process besides the decision; substantive reasonableness, which deals with the matter, and the manner the decision made, and proportionality, which is connected with the issue of whether the action by the administration is relevant to its objective. The harmony of the three above-mentioned dimensions creates a reliable architecture to the review of administrative acts.

The doctrine of reasonableness assumes different tasks and responsibilities in the administrative law sector. It functions as the instrument according to which judicial reviews on the part of administrative decisions can be made, hence, enabling courts to step in when the authorities have crossed their limits or have acted in an irrational way. It also advances the way transparency and responsibility are guaranteed in governance as it makes administrators comply with reasoned decisions. Most importantly, it safeguards citizens from being subject to arbitrary state actions through the requirement of administrative powers to be exercised in accordance with law and the principles of natural justice.

This study is about the changes in the doctrine of reasonableness due to the decisions made by the courts, especially the Supreme Court decisions that have been the main factor for the transformation of the doctrine and the way it has been used in courtrooms. It delves into the conceptual framework of the doctrine, its alignment with the key principles of the constitution, and the real-life execution in the diverse fields of administrative decision making.

RESEARCH PROBLEM

The doctrine of reasonableness in administrative law has been recognized as a crucial safeguard against arbitrary exercise of power. However, its implementation and effectiveness face several challenges in the contemporary administrative context. This research addresses the following problems:

1. Despite the conceptual clarity of the doctrine of reasonableness in judicial pronouncements, there remains ambiguity in its practical application across various administrative contexts. Courts have sometimes adopted inconsistent approaches to reviewing administrative decisions, leading to uncertainty about the scope and standards of reasonableness.
2. The increasing complexity of administrative governance and specialized regulatory frameworks has raised questions about the appropriate level of judicial intervention under the reasonableness doctrine. This creates tension between respecting administrative expertise and discretion while ensuring protection against arbitrary action.

RESEARCH QUESTIONS

1.      How has the doctrine of reasonableness evolved in Indian administrative law, and what are its theoretical foundations?

2.      To what extent has the doctrine of reasonableness been effective in preventing arbitrary administrative action in India?

3.      What are the challenges in applying the doctrine of reasonableness to modern administrative decision-making processes, and how can they be addressed?

4.      What reforms or refinements to the doctrine of reasonableness are necessary to strengthen its role as a safeguard against administrative arbitrariness?

HYPOTHESIS

The doctrine of reasonableness, despite its long-standing recognition in administrative law, faces significant challenges in effectively constraining arbitrary administrative action in contemporary governance systems. This research proposes two main hypotheses:

1.      Inconsistent judicial application, respect to administrative competence, and complicated decision-making procedures restrict the usefulness of the reasonableness concept against administrative arbitrariness. Despite its potential as a protective mechanism, these characteristics may limit its actual effectiveness in restricting action.

2.      A structured and multidimensional approach to reasonableness review, including procedural fairness, substantive rationality, and proportionality, can effectively limit arbitrary administrative action while respecting legitimate discretion and expertise.

CONCEPTUAL FRAMEWORK OF THE DOCTRINE OF REASONABLENESS

Historical Evolution of the Doctrine

The doctrine of reasonableness is a well-rooted ideain all legal systems around the world, which can be traced to the initial notions of fairness and justice and from there, to be formulated as its modern convenient standard for reviewing administrative action. The evolution of the doctrine of reasonableness in the Indian context is quite visible, passing through the several phases reflecting the relationship between the judiciary and the administrative state that changed from time to time.

It is the era when it was a colony, the period of British rule, where administrative decisions could be hardly challenged by the judiciary with the help of the doctrine of crown privilege. Following the independence of India, however, the Indian judiciary had started developing their local principles of administrative law whilst relying on English common law and adjusting it to India's constitutional framework. The Supreme Court's initial decisions in the 1950s and 1960s were the beginning of establishing reasonableness as a ground for reviewing administrative action, especially in cases involving fundamental rights.

A significant turning point came with the landmark case of E.P. Royappa v. State of Tamil Nadu (1974)[1], where Justice V.R. Krishna Iyer established the principle that administrative action must not be arbitrary and must be based on reason. The Apex Court held that:

21…"From a positivistic point of view, equality is antithetic to arbitrariness. In fact, equality and arbitrariness are sworn enemies. Where an act is arbitrary it is implicit in it that it is unequal both according to political logic and constitutional law and is therefore violative of Article 14."

The decision indicated a shift from the previous formalistic method of administrative review to a stage where substantive reasonableness was imposed as one of the constitutional requirements under Article 14. Later cases, including Maneka Gandhi v. Union of India (1978)[2], also helped in extending the ambit of the reasonableness standard in the judicial review of administrative actions, thus making it an essential feature of Indian administrative jurisprudence..

Theoretical Foundations of Reasonableness

The doctrine of reasonableness draws its theoretical legitimacy from several interconnected principles:

1. Rule of Law: At its core, the doctrine of reasonableness is an expression of the rule of law, which requires government action to be constrained by established legal principles rather than arbitrary will. Administrative decisions must be based on discernible legal standards and rational considerations, not whim or caprice.
2. Natural Justice: The doctrine embodies principles of natural justice, particularly the right to fair treatment. It ensures that administrative decisions are made through fair procedures and are substantively just, reflecting a sense of fairness that transcends mere procedural compliance.
3. Constitutional Values: In India, the doctrine is firmly anchored in constitutional principles, particularly Article 14 (equality before law), Article 19 (reasonable restrictions on fundamental freedoms), and Article 21 (protection of life and personal liberty). These provisions have been interpreted to mandate reasonableness in state action.
4. Democratic Accountability: The doctrine reinforces democratic governance by ensuring that administrative actions, though often taken by unelected officials, remain accountable to democratic values and respect citizen’s rights. It serves as a mechanism for controlling delegated power in a democratic system.
5. Separation of Powers: While acknowledging the distinct roles of different branches of government, the doctrine represents a judicial check on administrative power, reflecting the principle of separation of powers and checks and balances.

Dimensions of Reasonableness in Administrative Law

The doctrine of reasonableness encompasses several distinct but interrelated dimensions:

1. Procedural Reasonableness: This dimension concentrates on the procedure for making administrative decisions. It means that fair process, adequate notice, hearing opportunity, and impartiality are necessary tasks. In Union of India v. Tulsiram Patel (1985)[3], the Supreme observed that

22..”procedural reasonableness is essential for the legitimacy of administrative action, particularly when it affects individual rights.”

1. Substantive Reasonableness: The area investigates the subject and basis of administrative decisions. This ensures that decisions are made with the use of relevant facts, evidence, and a logical relationship between the facts and the decisions. In Tata Cellular v. Union of India (1994)[4], the Supreme Court held that

31..“Administrative decisions must be based on rational considerations and not arbitrary factors.”

1. Proportionality: This dimension assesses whether an administrative measure is proportionate to its objective. It requires that restrictions on rights be necessary, suitable, and not excessive in relation to the purpose sought. In Om Kumar v. Union of India (2000)[5], the Supreme Court explicitly observed proportionality as an aspect of reasonableness review, particularly in cases involving fundamental rights.
2. Legitimate Expectations: This dimension ensures the legitimate expectations of people from administrative practices, policies or representations are not violated.. In Food Corporation of India v. Kamdhenu Cattle Feed Industries (1993)[6], the Apex Court held that

22…“Administrative authorities must respect legitimate expectations unless there is an overriding public interest justification for departing from them.”

1. Rationality: This dimension requires that administrative decisions be rationally connected to the purpose for which the power was conferred. In Barium Chemicals Ltd. v. Company Law Board (1966)[7], the Court held that

11…“subjective satisfaction of administrative authorities must be based on objective facts and rational inferences.”

Understanding these dimensions is crucial for comprehending the full scope and potential of the doctrine of reasonableness as a safeguard against administrative arbitrariness. It provides a framework through which courts can systematically review administrative actions while respecting the expertise and discretion of administrative bodies.

CONSTITUTIONAL AND LEGAL FOUNDATIONS OF THE DOCTRINE

Constitutional Provisions and Reasonableness

The doctrine of reasonableness in Indian administrative law derives its authority primarily from the Constitution, which contains several provisions that directly or indirectly mandate reasonableness in state action:

1. Article 14 - Equality Before Law: This provision has been interpreted to prevent any kind of arbitrary action by the state. In Ajay Hasia v. Khalid Mujib (1981)[8], the Supreme Court held that Article 14 strikes at arbitrariness in state action and ensures fairness and equality of treatment. The Court held:

10…"The principle of reasonableness, which legally as well as philosophically is an essential element of equality or non-arbitrariness, pervades Article 14 like a brooding omnipresence."

1. Article 19 - Fundamental Freedoms: Clauses (2) to (6) of Article 19 explicitly allows only "reasonable restrictions" on the fundamental freedoms guaranteed under clause (1). The Supreme Court in Chintaman Rao v. State of Madhya Pradesh (1950)[9] defined reasonable restrictions as those that strike a proper balance between the freedom guaranteed and the social control permitted by the Constitution. This constitutional standard directly incorporates reasonableness as a criterion for evaluating administrative actions that restrict fundamental freedoms.
2. Article 21 - Protection of Life and Personal Liberty: After the landmark decision in Maneka Gandhi v. Union of India (1978)[10], Article 21 has been interpreted to require that any procedure that deprives a person of life or personal liberty must be "just, fair and resoanble," not arbitrary or fanciful. This expanded interpretation infused the concept of substantive reasonableness into Article 21.
3. Article 32 and Article 226 - Writ Jurisdiction: Such provisions empower the High Courts and the Supreme Court, respectively, to issue writs for the enforcement of fundamental rights. Within this writ jurisdiction, the courts have used the doctrine of reasonableness as a ground for the judicial review of administrative action.

Statutory Framework and Reasonableness

Various statutes incorporate the principle of reasonableness, either explicitly or implicitly:

1.      Right to Information Act, 2005: That particular law is designed to encourage openness in the act of governing and conveys that the officials requires detailed explanations as per the statute to justify decisions, which in turn encourages reasonable decision-making on a non-direct base.

1. General Clauses Act, 1897: Section 16 of this Act provides that powers conferred on administrative authorities must be exercised "reasonably and in good faith," establishing a statutory basis for the reasonableness requirement.

Judicial Interpretation and Development

The doctrine of reasonableness has been significantly shaped and refined through judicial decisions:

1. Early Development: In State of Madras v. V.G. Row (1952)[11], the Supreme Court held that

16…”courts must determine the reasonableness of restrictions on fundamental rights by considering factors such as the nature of the right infringed, the purpose of the restriction, the extent of urgency, and the prevailing conditions at the time.”

1. Wednesbury Principle: The Indian judiciary has evolved itself with English Wednesbury principle, which holds that administrative action is unreasonable if it is so absurd that no reasonable person could have arrived at it. In Barium Chemicals Ltd. v. Company Law Board (1966), the Court applied this principle to scrutinize administrative discretion.
2. Reasoned Decision-making: In S.N. Mukherjee v. Union of India (1990)[12], the Supreme Court observed that:

11…“Importance of reasoned decisions in administrative proceedings, stating that the giving of reasons is an essential part of administrative justice and promotes transparency and accountability.”

1. Evolving Standards: In recent years, the Court has moved towards a more intensive form of reasonableness review. In Cellular Operators Association of India v. TRAI (2016)[13], A proportionality approach was employed by the Court where regulatory measures would be considered necessary and proportionate to their goals, indicating a more systematic method of reasonableness review.
2. Expanding Scope: The Supreme Court in Shayara Bano v. Union of India (2017)[14]explicitly recognized "manifest arbitrariness" as a ground for invalidating legislation under Article 14, extending the reasonableness review to legislative action as well.

APPLICATION OF THE DOCTRINE IN JUDICIAL REVIEW

Standards of Judicial Review

The application of the doctrine of reasonableness in judicial review of administrative actions has evolved to include several distinct standards, each representing a different level of scrutiny:

1. Traditional Wednesbury Unreasonableness: This standard, derived from the English case of Associated Provincial Picture Houses Ltd. v. Wednesbury Corporation (1948), represents the most deferential form of reasonableness review. Under this standard, courts intervene only if an administrative decision is so unreasonable that no reasonable authority could have made it. In Indian Aluminium Co. v. Kerala State Electricity Board (1975)[15], the Supreme Court applied this standard, emphasizing that courts should not substitute their judgment for that of administrative authorities in matters of policy.
2. Enhanced Scrutiny: Courts have come up with an intermediate standard of review which is more rigorous than the traditional Wednesbury unreasonableness. One such example is the case of Tata Cellular v. Union of India (1994)[16], where the court applied a reformed strategy in assessing administrative discretion, looking at qualifying only those factors that were, unqualifying only those that were irrelevant, and finally, at the same time, the decision was in no way motivated by an illegal purpose.
3. Proportionality: This standard represents the most intensive form of reasonableness review and is increasingly applied in cases involving fundamental rights. In Om Kumar v. Union of India (2000)[17], the Supreme Court explicitly recognized proportionality as a distinct standard of review, requiring administrative actions to be suitable, necessary, and balanced in relation to their objectives. The Court held:

22…"The principle of proportionality requires the Court to judge whether the legislature and the administrative authority have maintained a proper balance between the adverse effects which the legislation or the administrative order may have on the rights, liberties or interests of persons keeping in mind the purpose which they were intended to serve."

Procedural and Substantive Aspects of Review

Courts apply the doctrine of reasonableness to both procedural and substantive aspects of administrative decision-making:

1. Procedural Reasonableness Review: The point here is whether a legitimate procedure was followed. In Mohinder Singh Gill v. Chief Election Commissioner (1978)[18], the Supreme Court held that

43…“in the absence of specific procedural guidelines a statute which grants discretion should not be used as a tool to the detriment of the principle of natural justice, thus making procedural reasonableness an implicit requirement.”

1. Substantive Reasonableness Review: This examines the content and basis of the decision itself. In E.P. Royappa v. State of Tamil Nadu (1974)[19], the Court established that

“administrative decisions must not be arbitrary and must be based on relevant considerations.”

“ Justice Bhagwati stated: "Equality is a dynamic concept with many aspects and dimensions and it cannot be 'cribbed, cabined and confined' within traditional and doctrinaire limits.”

1. Integrated Approach: The current form of judicial review heavily relies on a combination of procedural and substantive elements. In the case of Reliance Airport Developers Pvt. Ltd. v. Airports Authority of India (2006)[20], the Court considered both the integrity of the bidding process and the rationality of the standards used. The process was interactive and thus a holistic approach to reasonableness review was mentioned.

REASONABLENESS AS A CONSTRAINT ON ADMINISTRATIVE DISCRETION

Nature and Scope of Administrative Discretion

Administrative discretion refers to the authority granted to administrative bodies to make decisions based on their judgment within the parameters set by law. This discretion is essential for effective governance in modern complex societies, allowing flexibility and adaptation to varying circumstances that cannot be anticipated by rigid legislative rules. However, uncontrolled discretion poses risks of arbitrariness and abuse.

The scope of administrative discretion varies across different domains of governance:

1.      Policy Formulation: The highest administrative levels of government are the ones that make the most crucial decisions concerning the formulation of new policies and regulations. The Supreme Court in the Delhi Development Authority v. Joint Action Committee (2008) [21]recognized and acknowledged the authority of the organizing bodies in local areas to establish development plans, but they added that the exercise of such a privilege must still be reasonable and with the public interest in mind.

2.      Technical and Scientific Judgments: Legal enforcement agencies often decide cases based on technical expertise and specialized knowledge. In the matter of Consumer Education and Research Centre v. Union of India (1995)[22], the judges of the Court discerned the extent to which the administrative authorities could exercise their discretionary powers to protect people's safety against industrial hazards and while they agree that the decisions are technical, they also emphasize the need for rationalness in safeguarding workers' health.

Legal Mechanisms Enforcing Reasonableness

Several legal mechanisms enforce the reasonableness requirement in administrative decision-making:

1. Judicial Review: Courts review administrative decisions for compliance with reasonableness standards through writ jurisdiction that are covered under Articles 32 and 226 of the Constitution. In Union of India v. Mohan Lal Capoor (1973)[23], the Supreme Court intervened to correct an unreasonable exercise of discretion in service matters.
2. Legislative Oversight: Parliamentary committees and audit mechanisms provide additional oversight of administrative discretion, requiring explanations for decisions that appear unreasonable.

Case Studies of Judicial Intervention

Examining specific cases illustrates how courts apply reasonableness to constrain administrative discretion:

1. Environmental Decision-making: In Vellore Citizens Welfare Forum v. Union of India (1996)[24], the Supreme Court reviewed environmental regulatory decisions, applying the principles of sustainable development and precaution as aspects of reasonableness in environmental governance. The Court held that:

12…“Even broad discretionary powers in environmental regulation must be exercised in accordance with these principles.”

1. Economic Regulation: In BALCO Employees Union v. Union of India (2002)[25], while generally deferring to governmental discretion in economic policy, the Court established that even policy decisions must be reasonable and not arbitrary. The Court held:

32…"It is not for the courts to consider relative merits of different economic policies and consider whether a wiser or better one can be evolved."

1. Land Acquisition: In Bondu Ramaswamy v. Bangalore Development Authority (2010)[26], the Court scrutinized land acquisition decisions, requiring authorities to demonstrate reasonable necessity and proper purpose, not merely assert their discretionary power.

CHALLENGES IN APPLYING THE DOCTRINE

The doctrine of reasonableness is a powerful tool used by courts to check unfair or arbitrary actions by the government. However, applying this doctrine is not always easy. There are several challenges involved, both in understanding what is “reasonable” and in using it correctly in modern situations.

Defining the Boundaries of Reasonableness

1. Unclear Meaning: The word "reasonableness" is flexible and can mean different things to different people. This makes it hard to define it in a clear and fixed way.
2. Subjectivity: What one person thinks is reasonable, another might not. So, decisions based on this idea often depend on personal judgment.
3. Different Situations, Different Standards: What is considered reasonable changes depending on the situation. For example, emergency decisions are judged differently than regular decisions. Similarly, technical matters are judged differently than welfare or social matters.
4. Changing Over Time: Society’s views change over time. So, what was reasonable 20 years ago might not be considered reasonable today. This means the doctrine must grow and adapt with society.

Contemporary Challenges in Application

1.      Technology and Automation: At the moment, there are many government decisions that are made by machines and artificial intelligence. As a result, it is now more difficult to evaluate the fairness and rationality of those decisions through ordinary criteria.

2.      Complex Regulations: Nowadays, different fields of governance (such as finance or heath care) have become very specialized with words, an element which has reached a level where it is difficult for the courts to decide what is reasonable involved to bear the complexity.

3.      Global Rules and Agreements: When the decisions made by states comply with international agreements, these decisions have to be in line with the standards followed around the world. This point of view often contradicts the expectations at the local level of what is rational.

4.      Public-Private Mixing: In the present time, numerous government functions are handed over to private companies or joint organizations. This makes it difficult to decide, first of all, if at all and in what ways the idea of reasonable doubt is applicable to these bodies.

Reform Proposals

1.      Step-by-Step Analysis: The Courts are in a position to adopt a more methodical approach to evaluate the decision in terms of its reasonableness. For example, they could verify the decision with or without the proper prerequisites, if the problem-solving was affected, if it was really necessary or genuinely required and if it was people-friendly.

2.      Different Rules for Different Areas: One possibility is to have specific rules for certain types of cases (environment, economy.) Creating different standards of environmental protection can be achieved by having some basic regulators that have to be followed in the decision-making process. The other sectors of the economy can have the different ones that are developed after a thorough research done by the professionals and that best suit the specific sector.

3.      Focus on Process: One way the Courts can delve deeper into the decision-making process they can observe the way the decision has been made – for example, by inquiring about people's consultation, asking whether appropriate evidence was used and so forth of course, in addition to just finding about the final outcome of the decision.

4.      Expert Bodies: The creation of independent entities and authorities with extensive knowledge and expertise in the field of the particular issues to offer advice on the decisions that are under review on the one hand makes it possible to take more careful and knowledgeable decisions and on the other hand facilitates the easier determination of the reasonable character of a particular decision.

CONCLUSION

In summary, the doctrine of reasonableness stands as a critical safeguard against administrative arbitrariness in India's constitutional democracy. This doctrine has evolved significantly through judicial interpretation, transforming from a narrow ground of review into a comprehensive framework for evaluating administrative actions across procedural, substantive, and proportionality dimensions.

The development of this doctrine reflects the judiciary's response to the expanding administrative state and the need to balance administrative efficiency with protection of citizens' rights. From the early articulation in E.P. Royappa to the sophisticated proportionality analysis in recent judgments, courts have progressively refined the standards for determining when administrative actions cross the line into arbitrariness.

Despite its evident strengths, the doctrine faces significant challenges in contemporary governance. The inherent ambiguity in defining reasonableness, the appropriate level of judicial deference to administrative expertise, and the complexities of modern administrative decision-making all complicate its application. Emerging forms of governance, including algorithmic decision-making, public-private partnerships, and transnational regulation, further test the traditional boundaries of reasonableness review.

The comparative analysis reveals that while different jurisdictions approach reasonableness through distinct doctrinal frameworks, they share common concerns about constraining arbitrary power while respecting administrative autonomy. The Indian approach, with its constitutional grounding and integration of international standards like proportionality, offers a robust framework but requires continued refinement.

To strengthen the doctrine's effectiveness, several reforms merit consideration: adopting more structured approaches to reasonableness review, developing context-specific standards for different administrative domains, emphasizing procedural safeguards, and enhancing institutional mechanisms for administrative accountability. These reforms could address current limitations while preserving the doctrine's essential function.

The doctrine of reasonableness remains indispensable in a democratic society committed to the rule of law. By requiring that administrative power be exercised rationally, fairly, and for proper purposes, it upholds the fundamental principle that in a government of laws, not of men, authority must always be constrained by reason. As administrative governance continues to evolve, so too must this vital doctrine, adapting to new challenges while maintaining its core purpose as a shield against arbitrary power.

Reference

[1]  1974 4 SCC 3

[2] (1978) 1 SCC 248

[3] Union of India v. Tulsiram Patel, (1985) 3 SCC 398

[4] Tata Cellular v. Union of India, (1994) 6 SCC 651

[5] Om Kumar v. Union of India, (2001) 2 SCC 386

[6] Food Corporation of India v. Kamdhenu Cattle Feed Industries, (1993) 1 SCC 71

[7] Barium Chemicals Ltd. v. Company Law Board, 1966 SCC OnLine SC 53

[8] Ajay Hasia v. Khalid Mujib Sehravardi, (1981) 1 SCC 722

[9] Chintamanrao v. State of M.P., 1950 SCC 695

[10] Supra at 2

[11] State of Madras v. V.G. Row, (1952) 1 SCC 410

[12] Snehasish Mukherjee v. Union of India, (2016) 15 SCC 307

[13] Cellular Operators Assn. of India v. Telecom Regulatory Authority of India, (2015) 4 SCC 309

[14] Shayara Bano v. Union of India, (2017) 9 SCC 1

[15] State of Kerala v. Indian Aluminium Co. Ltd., (1999) 5 SCC 70

[16] Supra at 6

[17] Supra at 5

[18] (2001) 2 SCC 386

[19] Supra at 1

[20] Reliance Airport Developers (P) Ltd. v. Airports Authority of India, (2006) 10 SCC 1

[21] DDA v. Joint Action Committee, Allottee of SFS Flats, (2008) 2 SCC 672

[22] Consumer Education & Research Centre v. Union of India, (1995) 3 SCC 42

[23] Union of India v. Mohan Lal Capoor, (1973) 2 SCC 836

[24] Vellore Citizens' Welfare Forum v. Union of India, (1996) 5 SCC 647

[25] Supra at 18

[26] Supra at 20