Natural justice and disclosure of adverse material: registration cancellation failed because inspection reports were not shared before the order.

A cancellation of a dealer's registration certificate cannot be sustained where the adverse order is based on inspection reports that were not supplied before the order was made. The tribunal noted that natural justice requires disclosure of all material relied on for an adverse administrative decision and a fair opportunity to rebut it. Because the reports on the business's existence at the declared place were withheld, the dealer was deprived of that opportunity, and the cancellation was set aside. The matter could be taken up again only after the inspection reports were furnished with the notice.

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Issues: Whether the cancellation of the registration certificate was valid when it was based on inspection reports that were not supplied to the dealer before the order was passed.

Analysis: The cancellation order rested on reports of the Assistant Sales Tax Officer regarding the existence of the business at the declared place. Those reports were not furnished to the petitioner, depriving him of an opportunity to meet the adverse material. The principle of natural justice requires disclosure of material relied upon for an adverse order and a fair chance to rebut it. An order cancelling registration cannot stand when passed on undisclosed reports without such opportunity.

Conclusion: The cancellation order was set aside, and the matter could be proceeded with again only after supplying the inspection reports along with the notice to the petitioner.

Ratio Decidendi: An adverse administrative order based on undisclosed material violates natural justice and is liable to be set aside.

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