Question

“The rules of natural justice were not confined to the narrow precincts of the prevailing definition of quasi-judicial functions.” This principle was laid down in which case?

• A. A.K. Kraipak v. Union of India AIR 1970 SC 150
• B. Ridge v. Baldwin (1964) A.C. 40
• C. Maradana Mosque Trustees v. Mahmud (1967) (1) A.C. 13
• D. Conway v. Rimmer (1968) A.C. 910

Hint:

"Kraipak" = Breaking the wall! It broke the wall between quasi-judicial and administrative functions, making "Fairness" the universal requirement for all state actions.

Answer 1

The Correct Option is A

Step 1: Understanding the Concept:
This landmark Indian Supreme Court judgment revolutionized Administrative Law by expanding the scope of "Natural Justice" beyond the strict, formal boundaries of "quasi-judicial" acts to include administrative actions.

Step 2: Detailed Explanation:
- Before A.K. Kraipak, the prevailing view was that natural justice rules only applied to bodies performing quasi-judicial functions.
- The Supreme Court in this case declared that the distinction between quasi-judicial and administrative acts was becoming blurred and that natural justice must apply to administrative processes to ensure fairness and prevent arbitrariness.

Step 3: Final Answer:
The principle was laid down in A.K. Kraipak v. Union of India. Option (A) is correct.

Answer 2

The quotation in the question describes a shift in Indian administrative law away from confining natural justice to quasi-judicial functions, and each option needs to be checked for whether it is the actual source of this principle.

1. Option (A) - A.K. Kraipak v. Union of India, AIR 1970 SC 150: In this case, the Supreme Court held that the dividing line between administrative and quasi-judicial functions had become blurred, and that natural justice must extend to administrative decisions as well, not just quasi-judicial ones. This is the exact principle and wording the question describes.
2. Option (B) - Ridge v. Baldwin (1964) A.C. 40: This English case is significant for reviving natural justice principles in the context of dismissal from office, but it is not the source of the specific formulation about natural justice not being confined to quasi-judicial functions as developed in Indian law.
3. Option (C) - Maradana Mosque Trustees v. Mahmud (1967): This Privy Council case dealt with natural justice in a different specific factual context and is not associated with this particular Indian doctrinal statement.
4. Option (D) - Conway v. Rimmer (1968) A.C. 910: This English case concerns Crown privilege and disclosure of documents in litigation, a wholly different subject matter unrelated to the scope of natural justice discussed here.

Only A.K. Kraipak matches both the doctrinal content and the Indian context of the quoted principle.

Hence, the correct answer is A.K. Kraipak v. Union of India AIR 1970 SC 150.