Delegation of quasi-judicial valuation powers is valid where the statute allows delegation of any Commissioner power.

The Madhya Pradesh High Court notes that where a municipal statute expressly permits delegation of any power conferred on the Commissioner, the delegation may extend to quasi-judicial functions unless the enactment clearly restricts it. The power to decide objections to valuation under Section 148 was treated as quasi-judicial, yet the presence of supervision and control did not invalidate delegation. The delegated officer's determination was regarded as an order of the Commissioner and was separately appealable. In the absence of any material showing bias or lack of jurisdiction, the delegated valuation orders were upheld and the challenge to them failed.

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Issues: Whether the Commissioner could delegate under Section 69(4) the power to decide objections to valuation under Section 148, including a quasi-judicial function.

Analysis: The provision empowering municipal officers to exercise the powers of the Commissioner was construed as authorising delegation of any power conferred on the Commissioner by the Act, without limiting it to administrative functions. The power under Section 148 to decide objections to valuation was accepted as quasi-judicial, but the existence of control and superintendence did not negate delegation. The delegated officer's order was treated as an order of the Commissioner under the Act and was separately appealable. No material was shown to establish bias or lack of jurisdiction in the Assessment Officer.

Conclusion: The Commissioner validly delegated the power to decide objections to valuation, and the orders passed by the Assessment Officer were not without jurisdiction.

Final Conclusion: The petitions challenging the delegated determination of valuation objections were rejected, and the impugned orders were upheld.

Ratio Decidendi: Where the statute expressly authorises delegation of any power of the Commissioner, such delegation may extend to quasi-judicial functions unless the enactment restricts delegation by clear implication or express limitation.

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