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Issues: Whether the Central Government, while disposing of a revision under the Mineral Concession Rules against an order of the State Government granting or refusing a mining lease, was bound to give reasons in support of its decision.
Analysis: The statutory scheme required the State Government to consider the prescribed criteria for grant of a mining lease, and the rules governing revision contemplated consideration of the revision application, comments of the parties, and counter-comments as the record of the case. The revisional power was therefore exercised in a quasi-judicial capacity. Where the revisional authority merely affirmed or rejected the State Government's order without disclosing the process of reasoning, the appellate court was left at a disadvantage in testing the legality and propriety of the decision. The requirement of reasons was reinforced by the availability of further challenge to the Supreme Court under Article 136, since effective judicial review depends upon knowledge of the grounds on which the decision rests.
Conclusion: The Central Government was required to make a speaking order and its bare rejection of the revision applications without reasons was improper.
Ratio Decidendi: A revisional authority exercising quasi-judicial power under the mineral concession regime must disclose the reasons for its decision, either directly or by clear adoption of the reasons of the original authority, especially where the order is subject to further judicial scrutiny.