Natural justice in renewal of statutory appointment required disclosed reasons, relevant material, and a fair opportunity before refusal.

Renewal of a statutory appointment under the Estate Duty Act depended on satisfaction of prescribed qualifications and experience on objective facts, making the decision open to judicial scrutiny. Vague and general reasons, unsupported by the record, could not justify an adverse inference that the petitioner lacked competence in the relevant fields. The authorities also failed to give a proper opportunity to meet the material relied upon against him, so the refusal was unsustainable, was set aside, and the matter was directed to be reconsidered according to law.

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Issues: Whether the refusal to renew the petitioner's appointment as a valuer under the Estate Duty Act was vitiated by extraneous considerations, non-application of mind, and breach of natural justice.

Analysis: Renewal of appointment under section 4(3) depended on satisfaction of the prescribed qualifications and experience under the relevant notification, and that satisfaction was open to judicial scrutiny on objective facts. The reasons communicated for refusal were found to be vague and general, and the record did not show how the petitioner failed to meet the prescribed criteria. The material relied upon by the authorities amounted, at best, to isolated valuation variations and did not establish lack of competence in the specified fields or justify an adverse inference about the petitioner's fitness. The petitioner was also not given a proper opportunity to meet the material used against him.

Conclusion: The refusal to renew the appointment was unsustainable and was set aside; the petitioner succeeded.

Final Conclusion: The impugned administrative decision was quashed, and the matter was directed to be reconsidered according to law.

Ratio Decidendi: A refusal to renew a statutory appointment based on objective qualifications and experience must rest on relevant, disclosed, and sufficient material; vague reasons, unsupported adverse inference, and denial of a fair opportunity render the decision vulnerable to judicial review.

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