Quasi-judicial independence and reasoned decision-making required where a revisional authority cannot rely on an administrative memo alone.

A quasi-judicial revisional authority must decide independently on relevant material and record reasons; it cannot treat an administrative memo as binding. The Tribunal noted that the authority rejected the revision solely on the basis of the memo, without independent application of mind or reasoned scrutiny. The revisional order was therefore illegal and invalid, was set aside, and the matter was remitted for fresh disposal by another Assistant Commissioner in accordance with law.

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Issues: Whether the revisional order was vitiated for having been passed by merely relying on an administrative memo and without independent reasons, and whether it was liable to be set aside and remitted for fresh disposal.

Analysis: The revisional authority was bound to exercise its quasi-judicial power independently and could not treat the Public Relations Officer's memo as binding. The earlier order of the Tribunal had specifically indicated that the memo was not to control the disposal of the matter. Instead of examining the issue on its own merits and recording reasons, the authority rejected the revision solely on the basis of that memo. Such an approach disclosed no independent application of mind and failed to furnish reasons that would enable superior scrutiny of the decision.

Conclusion: The revisional order was illegal and invalid, was set aside, and the matter was remitted for fresh disposal by another Assistant Commissioner in accordance with law.

Ratio Decidendi: A quasi-judicial authority must decide independently on the basis of relevant material and record reasons for its conclusion; it cannot dispose of the matter by treating an administrative memo as binding.

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