Reasoned orders in company name disputes are mandatory; a non-speaking order without reasons was quashed.

An order under section 22 of the Companies Act, 1956 that affects a company's name and entails civil consequences must be reasoned and comply with natural justice. Where the authority merely reproduces rival submissions without explaining why they were accepted or rejected, the order is a non-speaking order and shows lack of proper application of mind. The impugned order was therefore unsustainable and was quashed, with the matter left open for reconsideration after hearing the affected party and recording reasons.

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Issues: Whether an order passed under section 22 of the Companies Act, 1956, affecting the company name, could be sustained when it contained no reasons and merely recorded the rival submissions.

Analysis: An order under section 22 that determines rights and results in civil consequences is quasi-judicial in character and must conform to the principles of natural justice. Where the authority has only reproduced the parties' submissions and has not disclosed any reasoning showing how those submissions were accepted or rejected, the order is a non-speaking order and indicates absence of proper application of mind. In such circumstances, the affected party is entitled to challenge the order for want of reasons.

Conclusion: The impugned order was unsustainable because it did not record reasons for the final decision under section 22.

Final Conclusion: The order was quashed, and the matter was left open for reconsideration after hearing the petitioner and recording reasons.

Ratio Decidendi: A quasi-judicial order under section 22 of the Companies Act, 1956 that entails civil consequences must be a reasoned order and cannot be sustained if it merely recites submissions without disclosing the basis of decision.

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