Natural justice in adjudication requires full disclosure of relied-upon documents and fair cross-examination before decision.

Denial of natural justice was found where the adjudicating authority failed to supply all relied-upon documents, including requested income-tax records and other materials, and did not consider cross-examination of named witnesses sought by the noticee. The long pendency of about ten years was also noted as aggravating prejudice to the defence through possible loss of records and fading memory. The adjudication was therefore treated as having been completed in gross breach of natural justice, and the matter was remanded for fresh decision after disclosure of documents, permission for cross-examination, and a reasonable personal hearing.

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Issues: Whether the adjudication order was vitiated for denial of natural justice because the relied-upon documents were not fully supplied and the requested cross-examination of witnesses was not permitted.

Analysis: The record showed that all relied-upon documents were not furnished to the appellants, despite a specific request for copies of the Income-tax records and other materials on which the show cause notice rested. The request for cross-examination of named witnesses was also not considered in the adjudication order. The matter had remained pending for an inordinate period of about ten years, which could prejudice the defence by loss of records and fading memory. In these circumstances, the adjudication was held to have been completed in gross violation of the principles of natural justice.

Conclusion: The adjudication order was set aside and the matter was remanded for fresh decision after supplying all relied-upon documents, permitting cross-examination of witnesses sought by the appellants, and giving a reasonable opportunity of personal hearing. The appellants succeeded.

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