Reasoned orders and natural justice require the Settlement Commission to address objections with reasons before fixing duty liability.

An unreasoned order of the Settlement Commission was held amenable to judicial review under Article 226 because reasons are an essential part of fair decision-making and natural justice. A brief rejection of the assessee's substantive objections did not disclose application of mind and prevented meaningful judicial review. The absence of reasons vitiated the order to the extent it determined duty liability, so that part of the decision was set aside and the matter was remanded for fresh consideration by a reasoned order.

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Issues: Whether the Settlement Commission's order, which rejected the assessee's contentions without reasons, could be sustained in writ jurisdiction and whether the matter required remand for fresh consideration.

Analysis: The order of the Settlement Commission was amenable to judicial review under Article 226 of the Constitution of India. The recording of reasons is an essential component of fair decision-making and a requirement of natural justice. A reasoned order enables meaningful judicial review and shows application of mind to the contentions raised. Where the Commission disposed of the assessee's substantive objections by a brief, unreasoned rejection, the decision-making process was not in accordance with law. The absence of reasons vitiated the order to the extent it determined the duty liability.

Conclusion: The impugned order was set aside to the extent it determined the duty liability, and the matter was remanded to the Settlement Commission for fresh consideration by a reasoned order.

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