Natural justice bars a reporting officer from completing an assessment in his own cause; orders were set aside.

A reporting officer cannot lawfully act as the assessing officer and complete the assessment where the same person has already made the report, because the rule against acting as a judge in one's own cause applies to judicial, quasi-judicial and administrative proceedings alike. An assessment made by that officer offends natural justice and cannot be sustained. The assessment order and the first appellate order were set aside, and the matter was left open for fresh action by another officer in accordance with law.

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Issues: Whether the reporting officer could lawfully act as the assessing officer and complete the assessment.

Analysis: The assessment was challenged on the ground that the same officer who had made the report also took up and completed the assessment proceedings. The rule against a person acting as a judge in his own cause applies to judicial, quasi-judicial and administrative proceedings alike. An assessment made by the reporting officer himself offends the principle of natural justice and cannot be sustained.

Conclusion: The assessment order and the first appellate order were set aside, and the matter was left open for fresh action by another officer in accordance with law.

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