Prior approval and deemed approval under municipal law require full disclosure to the Standing Committee before statutory time limits run.

Prior approval under Section 73(c) of the Mumbai Provincial Municipal Corporation Act is a substantive statutory safeguard, so the Standing Committee must receive relevant tender records when supplied material is insufficient for meaningful scrutiny. The proviso creating deemed approval after fifteen days is a strict exception intended to prevent delay, but it cannot operate in a vacuum or defeat the Committee's function. The Commissioner could not justify withholding documents through later affidavits, and the alternative-remedy and locus objections did not bar writ relief. The Commissioner was therefore required to place the documents before the Committee, and deemed approval was unavailable on the facts.

---

---

Issues: Whether the Commissioner was bound to place before the Standing Committee the relevant tender documents and connected materials for effective consideration of a proposal requiring prior approval under Section 73(c) of the Mumbai Provincial Municipal Corporation Act, 1949, and whether deemed approval could validly be invoked without such disclosure.

Analysis: Prior approval of the Standing Committee under Section 73(c) is a substantive statutory safeguard and not an empty formality. The Committee must apply its mind in public interest, and for that purpose it is entitled to the relevant records when the documents already supplied are insufficient for meaningful scrutiny. The proviso to Section 73(c), which creates a deeming fiction after fifteen days, is an exception meant to prevent delay and must be construed strictly and in a workable manner; it cannot be used in vacuum or to defeat the Committee's statutory function. The Commissioner could not justify non-disclosure by later affidavits, especially when no such stand was taken in the earlier communication and when the stated objections were found to be unjustified or irrelevant. The Court also held that the Committee's right to seek the documents was supported by the applicable working rules and that the alternative-remedy and locus objections did not defeat the writ petition.

Conclusion: The Commissioner was required to place the sought documents before the Standing Committee, and the deemed approval could not be invoked on the facts.

---