Limited judicial review in post-equation matters: affected officers' representations considered, natural justice objection rejected, and administrative equation upheld.

In service equation under the States Reorganisation Act, 1956, the Central Government's determination was sustained because affected officers were later given an opportunity to make representations, and those representations were considered with the State Government's comments and the Advisory Committee's recommendations; the earlier absence of opportunity was treated as cured. The challenge based on breach of natural justice therefore failed. On the merits, the Court held that post-equation in reorganisation matters cannot be fixed with mathematical precision and judicial review is limited to whether the authority acted within the statutory framework on relevant material. As no irrelevant or extraneous consideration or mala fides was shown, the equation of posts was upheld and the High Court's interference was set aside.

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Issues: (i) Whether the Central Government's equation of the sales tax officers was vitiated for failure to follow the principles of natural justice and for not properly considering the representations of affected officers; (ii) whether the equation of the posts was irrational or based on irrelevant and extraneous considerations.

Issue (i): Whether the Central Government's equation of the sales tax officers was vitiated for failure to follow the principles of natural justice and for not properly considering the representations of affected officers.

Analysis: The statutory scheme required the Central Government to ensure fair and equitable treatment to affected officers and to give proper consideration to their representations while integrating services under the States Reorganisation Act, 1956. The record showed that the officers concerned were given an opportunity to submit representations before the later order was passed, and those representations were considered along with the comments of the State Government and the recommendations of the Central Advisory Committee. The absence of an earlier opportunity was treated as cured by the subsequent proceedings.

Conclusion: The challenge based on breach of natural justice failed.

Issue (ii): Whether the equation of the posts was irrational or based on irrelevant and extraneous considerations.

Analysis: The Court held that the equation of posts in an inter-State reorganisation cannot be determined with mathematical precision and that judicial review is limited to seeing whether the authority acted within the statutory framework and on relevant material. The Central Government had considered the accepted criteria, the representations of both sets of officers, the State Government's comments, and the Advisory Committee's recommendations. No mala fides were alleged, and no irrelevant or extraneous factor was shown to have influenced the decision.

Conclusion: The equation of posts was upheld as a valid administrative determination.

Final Conclusion: The High Court's interference with the Central Government's orders was unwarranted, and the equation of the posts made under the statutory scheme was restored.

Ratio Decidendi: In matters of equation of posts under a reorganisation statute, the Court will not substitute its own view if the authority has acted on relevant considerations, given affected officers an opportunity to represent, and properly considered those representations within the statutory framework.

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