Statutory eligibility cannot be narrowed by implied disqualifications, public perception, or extra procedural requirements in appointments.

A statute prescribing eligibility for appointment to the National Human Rights Commission cannot be supplemented by implied disqualifications drawn from the Paris Principles, United Nations resolutions, public perception, or alleged institutional bias. The governing text required only knowledge of, or practical experience in, human rights, and did not exclude former police officers or civil servants. The appointment mechanism was also held to be complete within the statute: no consultation with the Commission Chairperson was required, and the process was not invalid merely because one committee member did not respond. Where the legislature has occupied the field, external principles or administrative practice cannot add conditions to the statutory scheme.

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Issues: (i) Whether a former police officer was ineligible for appointment as a Member of the National Human Rights Commission under the governing statute despite reliance on the Paris Principles and United Nations resolutions; (ii) whether public perception or alleged institutional bias against the police could be used to read an implied disqualification into the statutory qualification; (iii) whether absence of consultation with the Chairperson of the Commission vitiated the appointment; (iv) whether the selection process was invalid because one member of the committee did not respond.

Issue (i): Whether a former police officer was ineligible for appointment as a Member of the National Human Rights Commission under the governing statute despite reliance on the Paris Principles and United Nations resolutions.

Analysis: The statutory qualification required only knowledge of, or practical experience in, matters relating to human rights. The language of the provision was plain and contained no exclusion of police officers or former civil servants. External principles and resolutions could not be used to add a disqualification that the statute itself did not express. The Court also noted that, once the field was occupied by parliamentary legislation, the municipal statute governed the appointment.

Conclusion: No statutory ineligibility was shown, and the appointment could not be invalidated on this ground.

Issue (ii): Whether public perception or alleged institutional bias against the police could be used to read an implied disqualification into the statutory qualification.

Analysis: The Court held that generalised criticism of the police force could not be treated as a legal basis for disqualifying an otherwise eligible person. Public opinion or perceived institutional bias had no role where the statute did not impose such a bar. The Court refused to convert broad social perceptions into an implied statutory exclusion.

Conclusion: Public perception did not create any disqualification, and this challenge failed.

Issue (iii): Whether absence of consultation with the Chairperson of the Commission vitiated the appointment.

Analysis: Section 4 provided a complete appointment mechanism through the statutory committee and did not require consultation with the Chairperson. The Court held that no further mandatory requirement could be imported into the statute. The absence of such consultation therefore did not affect validity.

Conclusion: The appointment was not vitiated for want of consultation with the Chairperson.

Issue (iv): Whether the selection process was invalid because one member of the committee did not respond.

Analysis: The statute prescribed no quorum, no mandatory meeting procedure, and no requirement that every member must respond. It expressly protected appointments from invalidation merely because of a vacancy in the committee. Since the remaining members concurred, the process was not defective.

Conclusion: The selection process remained valid.

Final Conclusion: The statutory challenge to the appointment failed in all material respects, and the writ petition was rejected.

Ratio Decidendi: Where a statute expressly prescribes the eligibility criteria and appointment procedure, the Court cannot read in an implied disqualification or additional procedural requirement on the basis of external principles, public perception, or administrative practice.

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