Statutory Commission of Inquiry upheld where government bona fide formed opinion and Article 14 challenge lacked supporting material.

A Commission of Inquiry may be appointed under Section 3 when the Government bona fide forms an opinion that inquiry into a definite matter of public importance is necessary, and judicial review is limited to mala fides, irrelevant considerations, irrationality, procedural impropriety, or non-application of mind. The Court found that prior reports did not prevent a fresh statutory inquiry, and the record showed due consideration and Council approval, so the challenge on mala fides, non-application of mind, and unreasonableness failed. The Article 14 discrimination claim also failed for want of factual material. The notification substantially survived scrutiny, though charges 4 and 14 required separate administrative attention.

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Issues: (i) Whether the impugned notification appointing a Commission of Inquiry was vitiated by mala fides, non-application of mind, or unreasonableness in the exercise of power under Section 3 of the Commissions of Inquiry Act, 1952; (ii) Whether the notification was discriminatory and violative of Article 14 of the Constitution of India.

Issue (i): Whether the impugned notification appointing a Commission of Inquiry was vitiated by mala fides, non-application of mind, or unreasonableness in the exercise of power under Section 3 of the Commissions of Inquiry Act, 1952.

Analysis: The power under Section 3 is an inquisitorial fact-finding power meant to enable the Government to collect information on a definite matter of public importance. Judicial review is confined to illegality, irrationality, procedural impropriety, bad faith, and decisions based on irrelevant considerations or non-application of mind. The existence of prior reports under an earlier executive arrangement did not bar the Government from forming a fresh opinion and ordering a statutory inquiry, especially where the files showed consideration of the material and approval by the Council of Ministers. On the record, the Government's decision was not arbitrary, mechanical, or perverse. However, the material relating to two charges stood on a different footing, namely the earlier finding on one charge and the absence of advertence to the vagueness found in another.

Conclusion: The notification was valid and lawful in respect of the charges other than charges 4 and 14, and the challenge on mala fides, non-application of mind, and unreasonableness failed.

Issue (ii): Whether the notification was discriminatory and violative of Article 14 of the Constitution of India.

Analysis: The plea of discrimination was not substantiated by the necessary factual material. The circumstances relating to the alleged comparable enquiry were not placed before the Court, and the record was insufficient to assess any claim of unequal treatment or hostile discrimination.

Conclusion: The Article 14 challenge was rejected.

Final Conclusion: The Original Petition failed. The impugned inquiry notification substantially survived judicial scrutiny, with only the treatment of charges 4 and 14 indicated as requiring separate administrative attention.

Ratio Decidendi: A statutory Commission of Inquiry may be appointed under Section 3 when the Government bona fide forms an opinion that an inquiry into a definite matter of public importance is necessary, and such administrative satisfaction is reviewable only on limited grounds such as mala fides, irrelevant considerations, irrationality, or non-application of mind.

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