Administrative appointment of trustees need not be a speaking order where no rival rights are adjudicated.

Appointment of trustees under section 15(1)(a) is an administrative power, not a quasi-judicial function, because it does not involve adjudication of rival legal rights or a lis between contesting parties. The governing test is whether the statute requires decision on objective criteria and a duty to act judicially; here, the relevant provisions only set eligibility, disqualification, and guiding factors such as the religious denomination and the founder's wishes, leaving discretion to the appointing authority. Revisional control under section 82 does not change that character. A speaking order was therefore not required, and the challenge to the trustees' appointment failed.

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Issues: Whether the Government, while appointing trustees under section 15(1)(a) of the Andhra Pradesh Charitable and Hindu Religious Institutions and Endowments Act, 1966, acts as a quasi-judicial tribunal and is therefore bound to pass a speaking order.

Analysis: The governing test for a quasi-judicial function is whether there is a lis between contesting parties, whether the authority is required to decide on objective criteria, and whether the statute imposes a duty to act judicially. In the present context, appointment of trustees was not a determination of rival legal rights between contesting parties. No person had a legal right to be appointed as trustee, and the statute did not require the appointing authority to adjudicate a dispute inter partes. Sections 15 and 16 supplied the relevant framework by prescribing eligibility, disqualification, and the need to have regard to the religious denomination and the wishes of the founder. The power was left to administrative discretion within those statutory guidelines. The existence of revisional control under section 82 did not convert the appointment power into a quasi-judicial one. The requirement of a speaking order therefore did not arise.

Conclusion: The power under section 15(1)(a) is administrative, not quasi-judicial, and the Government is not required to make the appointment by a speaking order.

Final Conclusion: The judgment of the High Court was set aside and the challenge to the appointment of the trustees failed.

Ratio Decidendi: Where a statutory power of appointment is exercised within prescribed guidelines and does not involve adjudication of rival rights or a duty to act judicially, the authority acts administratively and need not give reasons as in a quasi-judicial order.

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