Prior participation in the same dispute disqualified an appellate committee member and vitiated the order for bias.

A member of a State Appellate Committee was disqualified from hearing an appeal where he had earlier participated as Chairman of the original committee that rejected the same exemption claim. The governing rule of natural justice requires an unbiased decision-maker, and prior involvement in the identical dispute created a reasonable likelihood of bias under the principle that no one may be a judge in his own cause. Sitting later on a multi-member appellate body did not cure the defect because he had already expressed an opinion on the matter under appeal. The appellate order was therefore vitiated for bias.

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Issues: Whether a member of the State Appellate Committee who had earlier participated as Chairman of the State Level Committee in rejecting the same exemption claim was disqualified from hearing the appeal on account of bias and the rule against acting as judge in his own cause.

Analysis: The impugned appeal was decided by a committee that included the same officer who had earlier sat on the original rejecting authority. The governing principle of natural justice requires an unbiased decision-maker, and the maxim that no one should be a judge in his own cause applies where prior participation in the same matter creates a reasonable likelihood of bias. The fact that the officer later sat in a different capacity on a multi-member appellate committee did not remove the disqualifying feature, because he had already expressed an opinion on the very dispute now under appeal. The participation of such a member was held to undermine the fairness and transparency required in quasi-judicial decision-making.

Conclusion: The officer was disqualified from sitting in appeal over the earlier decision in which he had participated, and the appellate order was vitiated for bias.

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