Relaxation power and administrative review upheld where statutory guidance, public interest, and judicial review limit discretion.

Rule 3 of the All India Services (Conditions of Service-Residuary Matters) Rules, 1960 was treated as a relaxation power meant to address undue hardship in unforeseen cases and to advance justice in the public interest; on that basis, it was held to be supported by the statutory scheme and not arbitrary or violative of Article 14. The Court also distinguished quasi-judicial decisions from purely administrative orders and held that review power need not be expressly conferred for administrative action, since government may revise such decisions subject to statutory limits, natural justice where rights are affected, and judicial review. The challenge therefore failed.

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Issues: (i) Whether Rule 3 of the All India Services (Conditions of Service-residuary matters) Rules 1960 conferred arbitrary and unguided power on the Central Government and was violative of Article 14 of the Constitution of India; (ii) whether the Central Government had power to review its earlier administrative orders in the absence of an express statutory provision.

Issue (i): Whether Rule 3 of the All India Services (Conditions of Service-residuary matters) Rules 1960 conferred arbitrary and unguided power on the Central Government and was violative of Article 14 of the Constitution of India.

Analysis: The relaxation power under Rule 3 was read in the context of the scheme of Section 3 of the All India Services Act, 1951 and the range of rules governing recruitment, discipline, seniority, leave and other service conditions. The provision was intended to relieve undue hardship in unforeseen cases and to secure justice and equity in the public interest, not to permit arbitrary favoritism. The Court held that sufficient guidance was available from the rule itself and from the statutory scheme, and that the exercise of relaxation power remained subject to judicial review.

Conclusion: Rule 3 was held to be constitutionally valid and not violative of Article 14.

Issue (ii): Whether the Central Government had power to review its earlier administrative orders in the absence of an express statutory provision.

Analysis: The principle requiring express conferment of review power was held applicable to quasi-judicial decisions, not to decisions of a purely administrative character. The Court held that Government must have freedom to alter or revise administrative policy and decisions, subject to statutory requirements, natural justice where rights are affected, and judicial review of the revised decision.

Conclusion: The Central Government was held to have power to review its earlier administrative orders.

Final Conclusion: The challenge to the impugned order failed, and the appeal was dismissed.

Ratio Decidendi: A relaxation power conferred for dealing with undue hardship in the public interest is not arbitrary merely because it is broadly worded, and the absence of an express statutory provision is not fatal to the review of a purely administrative decision.

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