Reasonable likelihood of bias in administrative selection vitiates the entire select list where a candidate sits on the board.

A statutory selection process is invalid where a member of the selection board is himself a candidate and participates in assessing rival candidates or framing the select list, because the conflict between interest and duty creates a reasonable likelihood of bias. The principle that no person should be a judge in his own cause applies even to administrative selection, and actual proof of bias is not required. Natural justice also governs administrative decisions with serious civil consequences, so a tainted foundational recommendation cannot be cured by later departmental or commission-level review. Where senior and junior scale selections form one integrated process, the defect may vitiate the entire select list.

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Issues: (i) Whether the selection process to the Indian Forest Service was vitiated by bias because a member of the selection board was himself a candidate and participated in the consideration of rival candidates and in the preparation of the select list. (ii) Whether the principles of natural justice applied to the administrative selection process and invalidated the recommendations and the final selections. (iii) Whether the vitiation of the selection process required setting aside the entire select list, including selections to both senior and junior scales.

Issue (i): Whether the selection process to the Indian Forest Service was vitiated by bias because a member of the selection board was himself a candidate and participated in the consideration of rival candidates and in the preparation of the select list.

Analysis: The governing principle is that no person should be a judge in his own cause. Even if the board's function were treated as administrative, the presence of a candidate on the board while rival cases were being considered created a conflict between interest and duty. The test was not proof of actual bias but whether there was a reasonable likelihood of bias. Participation in the deliberations and in framing the order of preference was enough to undermine impartiality.

Conclusion: The selection process was vitiated by reasonable likelihood of bias and was invalid.

Issue (ii): Whether the principles of natural justice applied to the administrative selection process and invalidated the recommendations and the final selections.

Analysis: The decision affirms that natural justice is not confined to strictly judicial or quasi-judicial proceedings. Administrative decisions producing serious civil consequences must be made fairly and without arbitrariness. The recommendations of the board were an important step in the statutory process, and once that foundational step was tainted, the later consideration by the Ministry and the Commission could not cure the defect.

Conclusion: The principles of natural justice applied, and their breach invalidated the recommendations and the resulting selections.

Issue (iii): Whether the vitiation of the selection process required setting aside the entire select list, including selections to both senior and junior scales.

Analysis: The senior and junior scale selections were made from the same pool and formed part of one integrated process. The taint affected the preparation of the select list as a whole, including the ranking of candidates, and the defect could not be confined to only a few individual candidates.

Conclusion: The entire selection list, including the selections to both scales, was liable to be set aside.

Final Conclusion: The statutory selection process was held unlawful for want of impartiality and fairness, and the impugned selections could not stand.

Ratio Decidendi: Where a statutory selection or recommendation process is participated in by a person who is himself a candidate, the resulting conflict of interest creates a reasonable likelihood of bias, and the process is invalid if that taint affects a material step in the decision-making chain.

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