Natural justice in mineral concession review requires disclosure of adverse material and a fair hearing before decision-making.

In reviewing an application under Rule 59 of the Mineral Concession Rules, 1949, the Central Government was required to consider the relevant record and any explanation from the State Government, and the process was treated as quasi-judicial because it affected rights. Fairness required disclosure of adverse material relied upon and a reasonable opportunity for the applicant to respond. A decision based on undisclosed material, without hearing the applicant, was inconsistent with natural justice and rendered the order invalid.

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Issues: Whether the Central Government, while dealing with a review application under Rule 59 of the Mineral Concession Rules, 1949, acted in a quasi-judicial capacity and was bound to disclose adverse material and afford the applicant a reasonable opportunity of hearing.

Analysis: The review power under the rules required the Central Government to consider the relevant records and any explanation offered by the State Government before making a decision. Since the authority was deciding an application affecting rights and was acting on material obtained from the State Government, fairness required that the applicant be informed of adverse matters relied upon and be given an opportunity to answer them. A decision reached on undisclosed material, without such opportunity, offended the principles of natural justice.

Conclusion: The Central Government acted in a quasi-judicial capacity and its order was invalid for breach of natural justice because the appellants were not given a reasonable opportunity of being heard.

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