Mass unfair means in an examination can justify cancellation without individual hearings when objective material supports the decision.

An examining authority may cancel an examination at a centre where objective material shows mass use of unfair means and the integrity of the process is undermined. The statutory power to determine and publish results, and to disqualify candidates for adequate reasons, supported the cancellation; in an emergency, the Chairman could act with co-extensive powers and the Board's later approval treated the action as that of the Board. Individual hearings were not required because the decision was directed at a tainted examination as a whole, not at identified candidates, and insisting on quasi-judicial hearings would be impracticable in such circumstances.

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Issues: (i) Whether the cancellation of the examination at one centre was invalid for want of a specific complaint or for want of competence in the Chairman to take the decision; (ii) Whether the cancellation was vitiated for breach of natural justice because the examinees were not given an individual hearing before the results were withheld and the examination was cancelled.

Issue (i): Whether the cancellation of the examination at one centre was invalid for want of a specific complaint or for want of competence in the Chairman to take the decision.

Analysis: The record showed that the tabulators noticed an abnormally high success rate, the matter was examined by the unfair means committee and moderators, and their reports supported action. The statutory scheme empowered the Board to determine and publish examination results and to disqualify candidates for adequate reasons. In an emergency, the Chairman's powers were co-extensive with those of the Board, and the action taken by him was later approved by the Board.

Conclusion: The cancellation was valid and was to be treated as an order of the Board.

Issue (ii): Whether the cancellation was vitiated for breach of natural justice because the examinees were not given an individual hearing before the results were withheld and the examination was cancelled.

Analysis: The cancellation was not directed against identified individuals but against an examination found to be vitiated on a mass scale. The materials, including answer-books and expert scrutiny, showed widespread use of unfair means. In such a case, insisting on a quasi-judicial inquiry and individual representation before cancelling the examination would be impracticable and unnecessary. The requirements of natural justice depend on the nature of the decision, and where the integrity of the entire examination is undermined, the examining authority may cancel it without proceeding against each candidate separately.

Conclusion: No breach of natural justice was made out.

Final Conclusion: The examining authority was entitled to cancel the tainted examination and the High Court's interference was unwarranted.

Ratio Decidendi: Where an examination at a centre is found to be vitiated by unfair means on a mass scale, the examining authority may cancel the examination without giving each candidate an individual hearing, and such action will not offend natural justice if the decision is supported by objective material and lies within the authority's statutory powers.

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