Stage-carriage permit appeals may admit additional information in discretion, if natural justice is observed and the parent Act is respected.

In a statutory stage-carriage permit scheme, the transport appellate tribunal may, consistent with public interest and natural justice, consider relevant additional information beyond material filed within the original statutory time-limit. Rule 15 of the Andhra Pradesh State Transport Appellate Tribunal Rules, 1971 was held to be within the parent Act because it only gives the Tribunal discretion to receive such material for a just decision; it does not create an automatic right to adduce extra evidence. The challenge to the rule was rejected and the rule was upheld as intra vires the Motor Vehicles Act, 1948.

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Issues: Whether Rule 15 of the Andhra Pradesh State Transport Appellate Tribunal Rules, 1971, which permits the Tribunal to receive additional evidence or information, is ultra vires Sections 47, 57 and 64 of the Motor Vehicles Act, 1948.

Analysis: The statutory scheme of stage-carriage permits is oriented to public interest. Section 47 requires the transport authority to choose the applicant best able to serve the public, and the enquiry is not confined to the private contest between applicants. Sections 57(3) and 57(4) regulate representations by interested persons, but they do not exhaust the sources from which the Tribunal may obtain relevant information. The Tribunal, acting quasi-judicially, may consider material bearing on the statutory factors if the affected party is given a fair opportunity to meet it. Rule 15 does not confer a right on parties to adduce extra material as of right; it only empowers the Tribunal to admit such material in its discretion for just decision-making. That procedure is consistent with the broader legislative purpose and with natural justice.

Conclusion: Rule 15 is intra vires the Motor Vehicles Act, 1948. The appeal fails and the challenge to the rule is rejected.

Ratio Decidendi: In a statutory permit scheme governed by public interest, an appellate transport authority may, in its discretion and subject to natural justice, receive and act upon relevant additional information not confined to representations made within the original statutory time-limit, so long as the rule enabling that course remains within the policy and framework of the parent Act.

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