Personal bias in quasi-judicial decision-making invalidated transport scheme approval where evidence supported disqualification.

A quasi-judicial decision under Section 68D(2) of the Motor Vehicles Act, 1939 must comply with natural justice, so the decision-maker must act objectively, fairly and impartially. Personal bias, if proved, disqualifies the authority from deciding the objections. On the affidavit evidence, allegations that the Minister had sought electoral support from the Managing Director, reacted adversely on refusal, and later dealt with the transport objections were substantially corroborated by surrounding circumstances and supporting affidavits. The High Court's appreciation of the evidence was left undisturbed, and the plea of personal bias was accepted, rendering the approval order invalid.

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Issues: Whether the Minister who heard objections and approved the transport schemes under Section 68D(2) of the Motor Vehicles Act, 1939 was disqualified for personal bias, so as to invalidate the impugned order.

Analysis: The matter was quasi-judicial and had to conform to the principles of natural justice. A decision-maker must act objectively, fairly and impartially, and a personal bias, if proved, disqualifies the authority from adjudicating the matter. On the evidence by affidavit, the allegations that the Minister had sought electoral support from the Managing Director, had become angered on failure, and later dealt with the transport objections, were found substantially corroborated by surrounding circumstances and by supporting affidavits. The denials were treated as evasive and unsatisfactory. The Court therefore saw no reason to interfere with the High Court's appreciation of the evidence.

Conclusion: The plea of personal bias was proved and the Minister was disqualified from dealing with the objections. The order approving the schemes was invalid, and the appeals were dismissed.

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