Natural justice in transport permit appeals depends on the statutory procedure, and reading an informational police report can suffice.

Natural justice before a statutory transport appellate authority is judged by the statute, the nature of the enquiry, and the procedure it prescribes, not by the full rules of civil court evidence. A police report used only as informational guidance, and not as direct adverse material against the opposing party, need not be separately supplied in every case if the report is read out at the hearing and no objection or request for adjournment is made. On that approach, the SC held that the hearing was fair, no breach of natural justice was shown, and the challenge to the appellate order failed.

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Issues: Whether the appellate transport authority breached the principles of natural justice by hearing the appeal after the police report was read out without supplying a copy to the parties or adjourning the matter for further response.

Analysis: The appeal arose under the Motor Vehicles Act scheme governing permits, which required the appellate authority to hear the appellant and the original authority and permitted notice to other interested persons, but did not prescribe a court-like procedure or the recording of evidence as in regular litigation. The police report was treated as information for the guidance of the transport authorities, not as material intended to be disclosed in every case to rival applicants. The report read out at the hearing did not directly contain adverse allegations against the respondent seeking to challenge the permit, and no objection or request for adjournment was made at the hearing by any party. In that statutory setting, the requirements of natural justice had to be measured by the nature of the tribunal and the procedure contemplated by the Act and rules, not by the full procedural safeguards of a civil court.

Conclusion: The reading of the police report in the appeal hearing was sufficient compliance with natural justice, and no failure of fair hearing was established. The challenge to the appellate order failed, and the appeal was allowed in favour of the appellant.

Ratio Decidendi: The content of natural justice for a statutory quasi-judicial tribunal depends on the statute, the nature of the enquiry, and the prescribed procedure; where the material relied on is only informational, does not directly prejudice the opposing party, and no contemporaneous objection or request for adjournment is made, disclosure in the manner adopted may amount to sufficient hearing.

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