Natural justice applies to examination disciplinary action when a statutory committee imposes serious career consequences.

A statutory examinations committee that must determine, on the materials before it, whether an examinee committed concealment, false statements, unfair means, fraud, moral offence or indiscipline acts quasi-judicially when imposing cancellation of results and exclusion from future examinations. Because such action carries serious stigma and grave career consequences, natural justice requires notice and a fair opportunity to be heard unless the statute clearly excludes it. The committee's failure to afford a hearing vitiates the adverse order.

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Issues: Whether the Examinations Committee, when acting under Rule 1(1) of Chapter VI of the Regulations, was required to act judicially and afford the examinee an opportunity of hearing before cancelling the examination result and debarring the examinee.

Analysis: The statutory scheme empowered the Board to constitute committees and to frame Regulations governing their powers and duties. Rule 1(1) authorised the Examinations Committee to consider cases of concealment, false statements, breach of rules, unfair means, fraud, moral offence, or indiscipline, and to impose penalties including cancellation of the examination and exclusion from future examinations. Although the Act and Regulations did not expressly prescribe a hearing, the Committee had to determine objectively whether one of the specified misconducts was established on the materials placed before it. The nature of the determination, the serious stigma attached to the decision, and its grave effect on the examinee's career showed that the Committee was not acting merely administratively but was performing a quasi-judicial function. In such a situation, the principles of natural justice required that the examinee be heard before adverse action was taken.

Conclusion: The Committee was bound to act judicially and to give the examinee a fair opportunity of being heard; the absence of such opportunity vitiated the order.

Final Conclusion: The appeal failed because the impugned action could not stand without compliance with natural justice, even though the Committee's function was not purely administrative.

Ratio Decidendi: Where a statutory committee must make an objective determination on materials before imposing serious penal consequences affecting rights and career, the function is quasi-judicial and the audi alteram partem rule applies unless excluded by statute.

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