Administrative power in university appointments: Chancellor's decision upheld, natural justice not required as an adjudicatory hearing.

The Chancellor's power under Section 31(8)(a) of the Uttar Pradesh State Universities Act, 1973, when resolving a disagreement between the Selection Committee and the Executive Council on an academic appointment, is administrative rather than quasi-judicial because the scheme contemplates no lis, hearing, or evidence-taking. Natural justice was therefore not required in the adjudicatory sense contended, although the decision remains subject to Article 14 and review for illegality, irrationality, arbitrariness, and extraneous considerations. The Court also accepted the appellant's eligibility, holding that the prescribed qualification allowed either a doctorate or published work of high standard, which the Selection Committee had accepted. The Chancellor's appointment order was upheld and the High Court's quashing was set aside.

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Issues: Whether the Chancellor's power under Section 31(8)(a) of the Uttar Pradesh State Universities Act, 1973 in resolving a disagreement between the Selection Committee and the Executive Council is administrative or quasi-judicial, and whether the Chancellor's appointment order in favour of the appellant was valid.

Analysis: The selection scheme placed the expert Selection Committee at the centre of appointment to academic posts, with the Executive Council having no power to substitute its own choice for that of the experts. When the Executive Council disagreed, the matter was referred to the Chancellor for a decision on the recommendation and the recorded disagreement, if any. The statutory setting did not provide for a lis between rival parties, any hearing, or taking of evidence before the Chancellor. The decision-making function was therefore held to be administrative in character, though still subject to Article 14 and the limits against illegality, irrationality, arbitrariness, and extraneous considerations. The Court also upheld the appellant's eligibility on the basis that the prescribed qualification permitted either a doctorate or published work of high standard, and the Selection Committee had accepted the alternative qualification.

Conclusion: The Chancellor's power under Section 31(8)(a) is not quasi-judicial but administrative, natural justice was not required in the manner contended, and the Chancellor's order appointing the appellant was valid.

Final Conclusion: The High Court's quashing of the Chancellor's decision was set aside, and the appellant's appointment as Reader in Psychology, with consequential benefits, was restored.

Ratio Decidendi: Where a statutory authority is called upon to act on the recommendation of an expert selection body and a recorded administrative disagreement, without any adjudicatory lis, hearing, or evidence-taking procedure, the power is administrative rather than quasi-judicial, though it remains subject to Article 14 and review for arbitrariness or illegality.

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