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A Note On One Who Hears Must Decide And Audi Alteram Partem

Natural justice norms have evolved with the advancement of civilisation, and their content is frequently used to assess the level of civilisation and Rule of Law in a given culture. To safeguard himself from the excesses of organised authority, man has always turned to someone outside of himself. Only God and his divine or natural law, to which all temporal laws and deeds must conform, may be such a person. This is where the concept of natural justice came from.

Fairness, rationality, equity, and equality are all aspects of natural justice. Natural justice is a concept in common law that is the common-law world's equivalent of the American 'procedural due procedures.' Natural justice refers to higher procedural norms defined by judges that must be followed by every administrative agency when making any judgement that affects a private individual's rights.

In India, the principles of natural justice are firmly grounded in Article 14[1] and 21[2] of the Constitution. Principles of natural justice are attracted whenever a person suffers a civil consequence or a prejudice is caused to him in any administrative action.

Mainly there are two principles:
  1. Nemo judex in causa sua, esse debet:
    no one is judge in his own cause, or the rule against bias.
  2. Audi alteram partem:
    no one should be condemned unheard.
Audi Alteram Partem: the rule of fair hearing
The notion of audi alteram partem is the foundation of natural justice. The term audi alteram partem simply means that everyone should have the opportunity to defend themselves. No one should be convicted without a hearing because of the doctrine's omnipotence. This concept has been applied to administrative action in order to offer fairness and justice to individuals who have been wronged. Its application is based on the factual matrix and is intended to improve administrative efficiency, expediency, and fairness.

The procedure ought to be fair and just. This is a principle that must be followed by every civilised community. This rule has a corollary: qui aliquid statuerit, parte inaudita altera aequum licet dixit, haud aequum facit, i.e., anyone who makes a decision without hearing the other side will not do what is right, even if he claims to be doing so. The rule of fair hearing applies to every stage of an administrative adjudication, from notification to final conclusion, because it is a code of procedure.
  1. Notice:
    The word 'notice' comes from the Latin word 'notitia,' which literally means 'to be known.' Any hearing begins with a notice. A person cannot defend himself unless he understands the subject and problems involved in the case. A decision made without notification is null and void from the start.

    The obligation of notice is neither statutory nor specified anywhere in India or England, but it is in the Administrative Procedures Act of the United States, Section 5(a). Management of Northern Railway Co-operative Society v. Industrial Tribunal Rajasthan,[3] the Supreme Court established the following requirements for notice:
    1. Notice to be clear, specific and unambiguous.
    2. Must contain time, nature and place of hearing.
    3. Must have statement of charges and must reveal other relevant material for the party.
    4. Must provide a reasonable opportunity to the other party.
    Failure to issue a notice when a statute clearly requires it renders the activity null and void. Under Article 22[4] of the Indian Constitution, detainees must be informed of the reasons for their incarceration, and if the reasons are vague, the detention order may be revoked by the court. The reasons for the proposed action must be exact, specific, and unequivocal in the notification. A notification is considered confusing if it just mentions the charges without saying what action will be done.

    A legal notice is an important tool for the parties to communicate with one another. A well-drafted legal notice can help parties resolve their differences without having to go through the formality of a formal legal procedure, saving both, time and money.
     
  2. Disclosure of Evidence-Right of Other Party to Know Evidence:
    Anyone facing an administrative authority with adjudicatory responsibilities has a right to know what evidence will be used against them. This premise was established in Dhakeshwari Cotton Mills Ltd v. CIT.[5] The department's information to the appellate income tax tribunal was not given in this case.

    According to the Supreme Court, the assessee was not allowed a fair hearing. A summary of the material's contents is sufficient, according to the court, as long as it is not misleading. Whatever approach is utilised, the essential concept remains the same: nothing should be used against someone who has not been informed of the situation.

    In Suresh Koshy v University of Kerala,[6] the question was whether the investigation report had to be released to the other party if the evidence has already been disclosed to the accused. The Supreme Court decided that non-disclosure does not imply that a person's right to know evidence has been violated because he knows the evidence in effect. Because they are institutional judgments for which a reasonable chance has been offered, disciplinary sanctions based on non-disclosed investigation reports are not in breach of the audi alteram partem. The report is not a proof, but rather a conclusion.

    Exception To Right To Know The Evidence:
    There may be times when the record is so large that sharing it with the accused is physically impossible. To deal with such a situation, Section 207[7] of CrPC's second proviso allows the magistrate to withhold extensive documents from the accused and merely allow inspection. However, this is the only codified basis for withholding documents from the accused. In all other circumstances, the accused must be given access to the materials relied on by the prosecution in order to have a fair trial. Many courts now order investigating agencies to create an electronic file containing extensive information and provide it to the accused.[8]

    What about any audio or video evidence that the prosecution may have? In most situations, the accused is entitled to a copy of the audio/video records that the prosecution is relying on. Because such records aren't 'voluminous,' they can't even be subject to the magistrate's discretion. What if, in cases of sexual offences, such records contain the identity of the woman victim? In the case of P Gopalkrishnan @ Dileep v. State of Kerala & Anr.,[9] the Supreme Court of India was asked to strike a balance between an accused's right to a fair trial and the victim's right to privacy and dignity. And how this is accomplished?

    Despite the fact that it is customary to provide a copy of all evidence relied on by the prosecution to the accused, the Apex Court made an exception in the above-mentioned instance, refusing to allow the accused to get a copy of the video due to the sensitivity of the crime. Exceptions like these can only be made based on the unique facts and circumstances of each instance.
     
  3. Opportunity to Rebut the Case:
    1. Cross Examination:
      This entitlement is based on the assumption that the defendant has been informed of the evidence against him. It's the most powerful method for eliciting and establishing truth. Cross-examination is not required in administrative adjudication unless the circumstances are such that the individual would be unable to make an adequate defence without it. According to the Supreme Court in Town Area Committee v. Jagdish Prasad,[10] the department filed the charge sheet, received an explanation, and then issued the dismissal decision right away.

      The ruling was overturned by the court, which stated that the right to a fair hearing includes the ability to question witnesses and submit evidence. In externment processes and hearings before customs authorities to ascertain whether objects were smuggled or not, however, the right to cross-examination was judged not to be an element of natural justice.
       
    2. Exception To Rule Regarding Cross Examination
      Three girls in the ladies' hostel complained to the principal in Hira Nath Misra v. Rajendra Medical College[11]case that boys jumped into the dorm by turning off the lights and molested them. An investigation committee was formed, and the girls used images to identify the boys. The lads were given the gist of the evidence by the committee without the names of the girls who had complained.

      The lads were charged and expelled as a result of the procedures. It was challenged in the Supreme Court on two grounds: the evidence was gathered without the participation of boys, and there was no opportunity for cross examination.

      The Supreme Court ruled that because there is a risk of future harassment, retaliation, and the like, cross examination is not required under certain situations. This is not, however, a general rule of exception and is usually exclusively applied in the setting of a school.
       
    3. Legal Representation
      Section 30[12] of the Civil Procedure Code in India contains this regulation. "Legal representation of right quality before the statutory tribunal is desirable," De Smith writes in his book Judicial Review, "and a person threatened with social or financial ruin by disciplinary proceedings in a purely domestic forum may be gravely prejudiced if he is denied legal representation."[13]

      The Supreme Court held in M.H. Hoskot v. State of Maharashtra[14] that the right to personal liberty entails the State providing free legal services to a prisoner who is indigent or otherwise unable to obtain legal assistance where the ends of justice require it, while importing the concept of "fair procedure" into Article 21[15] of the Constitution. In Khatri v. State of Bihar,[16] it was decided that even if accused persons are held in detention before trial, they should have legal representation. Under the Industrial Disputes Act, legal representation is also a legal entitlement. The Factories Act, on the other hand, makes it illegal, while other laws remain mute.

      Because oral hearing is not included in the basic standards of fairness, legal counsel is not considered an important part of the rule of natural justice in most administrative hearings. Attorneys tend to compound problems, lengthen processes, and detract from the proceedings' core informality; therefore this refusal of legal assistance is fair. It's also defended on the grounds that having one's own counsel gives the wealthy an advantage over the poor, who can't afford a good lawyer.
       
  4. No Evidence should be Taken in the Absence of the Other Party:
    The court evaluated how ex parte testimony obtained in the absence of the other party violates the principle of fair hearing in Errington v. Minister of Health.[17]Jarrow Corporation, according to the facts, issued a clearing order in 1933 for the demolition of several structures deemed unfit for human occupancy and submitted it to the Ministry of Health for approval. The owners of the building were given a hearing after an investigation was performed.

    The owners were not told of the visit, so some ministry workers returned to the spot and collected evidence. After examining the information gathered, the minister confirmed the clearance order. The clearance judgement was overturned by the court after a challenge, and one of the reasons provided was that the ex parte remarks made in the absence of the other party without giving the other party an opportunity to respond violated established natural justice rules.

    In Hira Nath Mishra v. Principle, Rajendra Medical College,[18] the Supreme Court reaffirmed this stance. In this case, the females at a medical college reported misbehaviour by the lads in the girl's hostel to the Principle. The girls' testimony was recorded by the Principle's inquiry committee, but the appellants were not present. The girls were also able to identify the appellants from the images.

    The committee found the appellants guilty and issued an expulsion order against them. The expulsion order was challenged in court, and one of the grounds was that the evidence was gathered behind their backs. The girls would not have made the remarks in front of the appellants unless they were extremely terrified of retaliation and harassment, according to the court. Whatever evidence was acquired behind the appellants' backs was brought to their attention in this case, and they were given the chance to contradict it.
     
  5. Right To Present The Case And Evidence:
    This can be done either verbally or in writing. According to the courts, an oral/personal hearing is not required for a fair hearing unless the circumstances are so peculiar that a person would be unable to mount an effective defence without it. As a result, in situations involving intricate legal and technical concerns or where the stakes are exceedingly high, oral hearing will become a component of fair hearing. As a result, in the absence of a statutory requirement for an oral hearing, courts will determine the outcome of each case based on its unique facts and circumstances.

    The court refused to overrule the President of India's order in Union of India v. J. P. Mitter,[19]finding that the President refused to allow an oral hearing even when sought in a dispute about the age of a high court judge. If a person is given the opportunity to submit his case in writing, the court found that there is no violation of natural justice principles if an oral hearing is not granted.

    In addition, the administrative authority must allow ample time for the presentation of evidence, whether testimonial or documentary. In Dwarkeshwari Cotton Mills Ltd. v. CIT,[20] the Supreme Court ruled that the administrative authority's decision was overturned because the assessee was denied the opportunity to provide relevant evidence, which violated the requirement of fair hearing.
     
  6. One Who Hears Must Decide:
    In one essential way, the judicial procedure varies from the administrative process. While the judiciary's sole function is to resolve disputes, an administrative authority may be required to do a variety of other tasks in addition to adjudication. As a result, in the instance of the two processes, two different adjudication methods have been adopted. A judge hears and determines his or her own cases, but this may not be the case with an administrative body. An administrative authority not only accepts, but is required to accept, the aid of subordinates in order to carry out the wide range of responsibilities entrusted to it.

    It's possible that one authority will hear and another will decide. This split in the decision-making process goes against the judicial process' essential notion, but it is unavoidable in the current administrative process. Administrative law's job is to reconcile the inevitability of the administrative process with fairness from the perspective of the individual.[21]

    Fundamental notions of fair play or natural justice, as they are known in the United Kingdom, or the doctrine of due process enshrined in the Fourteenth Amendment of the United States Constitution, or the requirement of clauses (5) and (6) of article 19 of the Indian Constitution that the State's restrictions on such rights must be reasonable and in the public interest.[22]

    In criminal and civil cases, the judge who handled the proceedings, heard evidence, and so on must conclude, according to Section 350 of the Criminal Procedure Code[23] and Order 18, Rule 15 of the Civil Procedure Code,[24] respectively. If a judge dies, gets transferred, or is otherwise prohibited from making a decision, the new judge can use the former judge's appreciation of evidence.

    An administrative action was challenged in Gullupalli Nageshwara Rao v. APSRTC[25] on the grounds that the person who makes the decisions did not listen. In this case, the petitioners challenged the government's order approving the road nationalisation scheme. The Secretary of the Department of Transportation presided over the hearing, but the Chief Minister made the final decision. The Supreme Court found that this shared responsibility breached the concept of fair hearing since the person making the decision will not be able to explain his uncertainties with reasoned thinking if he does not hear the opposing side.

    In administrative law, this principle stems from Lord Denning's minority opinion in Lord Denning in Breen v. Amalgamated Engineering Union[26] which concluded that the person who hears must decide. Where a member was missing, a domestic trade union tribunal made a decision after hearings. Lord Denning overturned House of Lords rulings, stating that there can't be 5 members hearing and just 4 members deciding.

    In American law, the term "institutional or anonymous decisions" relates to the principle of "one who decides must hear," which is popular in common law states. Many administrative proceedings, unlike law courts, are not decided by a single person from start to finish. Often, one individual hears something and then makes a decision. The distribution of tasks may be detrimental to the concept of a fair hearing.

    Only the individual who has heard the arguments and facts, as well as observed the demeanour of witnesses, if any, is qualified to make an informed judgement. This guideline is also intended to reassure the complaining party that he has had every opportunity to convey his point of view to the person who matters most. As a result, justice would not only be served, but it would also appear to be served.
     
  7. Reasoned Decision/Speaking Order:
    In India, unless there is a specific statutory need, administrative authorities are not required to provide explanations for their decisions. If the statute under which the agency operates requires reasoned decisions, courts consider it mandatory for the agency to provide reasons, which should not be "rubber-stamp" reasons but a brief, clear statement establishing a link between the material on which certain conclusions are based and the actual conclusions.

    The Supreme Court of India declared in Somdatt Dutta v Union of India[27]that, despite the lack of provisions, a court martial must disclose reasons. As a result, if a confirming authority makes a decision that is consistent with the original, there is no need to provide new grounds. If the confirming authority disagrees, reasons must be provided.

    Similarly, if the appellate authority deviates from a previous or initial ruling, grounds must be provided. The necessity of a reasoned conclusion must be followed by quasi-judicial and administrative agencies. This case also altered the position created by Tarachand[28]. Reasons must now be presented only when an institutional authority's decision is opposed to the inquiry report.

    The need for reasons to be recorded is greater when the order is passed in the initial stage. If the appellate or revisional authority confirms the challenged order, the appellate or revisional authority does not need to give separate reasons if the grounds in the challenged order are acceptable to the appellate or revisional authority. Unless the responsibility has been waived expressly or by necessary inference, an administrative agency possessing judicial or quasi-judicial powers is required to record the reasons for its judgement.
     
Exception To Reasoned Order:
The Supreme Court held in State of Maharashtra v. Salem Hasan Khan[29]that in circumstances when supplying reasons will contradict the aim of the ruling, reasons may be excluded. In this instance, the order was issued to safeguard the evidence and witnesses from the defendant, and the Supreme Court decided that if grounds could not be provided, the order would not be invalidated.

Exceptions to the Rule of Natural Justice
The term "exception" in the context of natural justice is a misnomer, because the audi alteram partem norm is held inapplicable to these exclusionary instances not as an exception to "fair play in action," but because there is nothing wrong with not providing an opportunity to present a case or meet. Hearing must be rare and exceptional in any civilised society. Natural law principles are employed. Justice can be omitted openly or by necessary inference under the Indian constitution Articles 14[30] and Article 21[31] if the standards of law are followed.

Some of The exceptions to rule of natural justice are mentioned below:
In Extraordinary circumstances of Urgency, where fast action, prevention, or remedial action is necessary, the requirement for notice and hearing may be waived. As a result, if the opportunity to be heard would obstruct the process, it would be prohibited by law. Post-decisional hearings are crucial for administrative and judicial gentlemanliness, even in an emergency situation concerning people's vital rights.

Otherwise, some form of pre-decisional hearing, no matter how rudimentary, must be offered, based on the facts of each case. The administrative decision to suspend natural justice norms due to an emergency situation is not final. The outcome of such a circumstance might be examined by court. The Hon'ble Supreme Court ruled in Malak Singh v. State of Punjab and Haryana[32]that the police surveillance record is a confidential document.

The person whose name is on the registry, as well as any other member of the public, are not allowed to look at it. Furthermore, the court ruled that adopting natural justice principles in such a situation may undermine the entire point of monitoring, and that there is a substantial likelihood that justice goals will be destroyed rather than realised.

In the case of Purely Administrative Matters, a university student was dismissed from the role without a pre-decisional hearing on the basis of poor academic performance. The Supreme Court ruled in Jawahar Lal Nehru University v. B.S. Narwal[33] that the nature of academic adjudication appears to preclude any right to a hearing. As a result, natural justice norms may be disregarded if competent academic authorities monitor and evaluate a student's work over time and declare it deficient.

However, this exemption does not apply to disciplinary matters or when the academic body performs non-academic duties. The court has to consider practicability of situation also. Where the Concept of Impracticality such as In R. Radhakrishnan v. Osmania University,[34] where the university cancelled the whole MBA entrance examination due to mass coping, the court determined that all candidates should be given notice and a hearing.

In a scenario that has grown to national proportions, it is not feasible. As a result, the court acknowledged the absence of Administrative Impracticability standards from natural justice principles.

If the administrative authority's action is a suspension order in the form of an Interim Preventative Measure rather than a final order, natural justice principles may be waived. In the case of Abhay Kumar v. K Srinivasan,[35] the university imposed an injunction barring the student from entering the campus or attending classes while he is facing criminal charges for stabbing a fellow student. Due to a lack of natural justice, this order was reversed.

While dismissing the claim, the Delhi High Court ruled that such an order might be compared to a prophylactic suspension pending investigation to safeguard campus peace. No applicability of principle of natural justice.

In cases of Legislative Actions as these laws define a policy without respect to a single individual, natural justice rules do not apply to legislative action, whether plenary or subordinate. Natural justice principles can also be excluded by a constitutional provision based on the same logic. The Indian Constitution specifically excludes natural justice concepts in Articles 22[36], 31A[37], 31B[38], 31C[39], and 311(2)[40].

Courts can overturn a legislative exclusion if it is arbitrary, unreasonable, or unfair, as stated in Articles 14 and 21 of the Constitution. The Supreme Court concluded in Union of India v. Cynamide India Ltd.[41] that the government did not breach any natural justice principles when it issued a notification regulating the price of certain drugs. Natural justice principles did not apply since the notification was based on a legislative act rather than an administrative one, the Court reasoned.

The principles of natural justice are not applicable when No Right Of The Person Is Infringed by any statute or where no such right arises from common law. In Andhra Steel Corporation v. A.P. State Electricity Board,[42] the court held that unless the law requires differently or the authority is bound by promissory estoppels, a concession can be cancelled at any time without providing affected parties an opportunity to be heard. If he is the only person competent or empowered to determine that case or take that action, he will not be disqualified on the basis of bias against him.

There will be no other way to address the matter if this exception is not given, and the entire government would come to a halt. The need, on the other hand, must be genuine and honest. The constitutional validity of the Bhopal Gas Disaster (Processing of Claims) Act, 1985,[43] was challenged the court dismissed the claim, holding that even if the logic was correct, the law of necessity would apply to the situation because no other sovereign power could represent the whole class of gas victims, and so natural justice standards would not be applied as being Statutory Exception or Necessity.

In the honourable Supreme Court concluded that natural justice grounds are not invoked when a contract is cancelled in any Contractual Field. In State of Gujarat v. M.P. Shah Charitable Trust,[44]the honourable Supreme Court decided that the termination of an arrangement/agreement is neither a quasi-judicial nor an administrative act, no judicial duty is generated.

If the executive powers provided to government are used to make policy choice than the natural justice principle are ignored as it would be Against Public Interest.

The Hon'ble Supreme Court of India concluded in Balco Employees Union v. Union of India.[45] The Court found that it cannot be challenged on the basis of natural justice principles unless the policy choice to disinvest is capricious, arbitrary, illegal, or ignorant, and does not run counter to the law.

Conclusion

The principle of natural justice has emerged since the beginning of mankind. The maxim "Audi Alteram Partem" is the foundation stone of natural justice. This maxim is based on the principle of just, fairness and equity. It is a broader concept than it appears and is one of the essential principles of natural justice; in fact, thinking about natural justice without considering the idea of audi alteram partem would be wrong.

It refers to the right to a fair hearing. This sentence may appear simple, yet it encompasses the entire tale of justice, from the delivery of notice to the post-decisional hearing. However, there are several instances where this rule is not observed. These exclusions, however, must be justified, there needs to be a rationale for ignoring this principle, which is the foundation of justice.

The aspects of this dictum, however, are eased under particularly extreme circumstances. The situation of emergency, impracticality, contractual arrangement, interim order, and so on is examples of these conditions. Considering the issue of deciding where to skip and where not to. There is no method for calculating this in a straitjacket. It is rather contingent on the facts and circumstances of the situation.

The presiding judge should strike a balance between the seriousness of both parties' facts and circumstances. But, based on the preceding examples, we may conclude that audi alteram partem, or the right to a fair hearing, is a universal idea. However, it should be recognised that even when the provisions are eased, justice always prevails.

End-Notes:
  1. India Const. art. 14
  2. India Const. art. 21.
  3. AIR 1967 SC 1182.
  4. India Const. art. 22.
  5. 1954/26 ITR 775 (SC).
  6. AIR 1969 SC 198.
  7. The Code of Criminal Procedure, 1973, 207, No. 2, Acts of Parliament, 1973 (India).
  8. Ansh Singh Luthra, Right of Accused to copies of Evidence v. Right to Privacy of Victim: A need for guidelines, Bar&Bench (Dec. 15, 2019, 10:00 AM), https://www.barandbench.com/columns/right-of-accused-to-copies-of-evidence-v-right-to-privacy-of-victim-a-need-for-guidelines.
  9. (2005) 11 SCC 45.
  10. (1979) 1 SCC 60.
  11. AIR 1973 SC 1260.
  12. Code of Civil Procedure, 1908, 304, No. 5, Acts of Parliament, 1908 (India).
  13. Kramer, R. Review of Judicial Review of Administrative Action, by S. A. de Smith, 12 J Legal Educ. 302, (1959).
  14. (1978) 3 SCC 544.
  15. India Const. art. 21.
  16. (1981) 2 SCC 493.
  17. (1934) All ER 154.
  18. AIR 1973 SC 1260.
  19. AIR 1957 Cal 190.
  20. 1954/26 ITR 775 (SC).
  21. Jain, S. N., The One Who Decides Must Hear. Journal of the Indian Law Institute, 16(3) 1974, 347-351. http://www.jstor.org/stable/43950373.
  22. Deshpande, V. S., "The One Who Decides Must Hear." Journal of the Indian Law Institute, 2 (3) 1960, 423-434. http://www.jstor.org/stable/43953766.
  23. Code of Criminal Procedure, 1974, 350, No. 2, Acts of Parliament of India, 1974 (India).
  24. Code of Civil Procedure, 1908, order 18, rule 15, No. 5, Acts of Parliament of India, 1908 (India).
  25. AIR 1959 SC 308 (29).
  26. 1971 (1) All ER 1148.
  27. AIR 1969 SC 414.
  28. Tarachand v. Delhi Municipality, AIR 1977 SC 567.
  29. (1989) 2 SCC 316.
  30. India Const. art. 14.
  31. India Const. art. 21.
  32. (1981) 1 SCC 420.
  33. (1980) 4 SCC 480.
  34. AIR 1974 AP 283.
  35. AIR 1981 Del 381.
  36. India Const. art. 22.
  37. India Const. art. 31A.
  38. India Const. art. 31B.
  39. India Const. art. 31C.
  40. India Const. art. 311(2).
  41. (1987) 2 SCC 720.
  42. (1991) 3 SCC 263.
  43. The Bhopal Gas Leak Disaster (Processing of Claims) Act, 1985, No. 21, Acts of Parliament of India, 1985 (India).
  44. (1994) 3 SCC 552.
  45. (2002) 2 SCC 333.


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