Bias challenges to transport permit orders need clear proof of disqualifying interest; mere suspicion does not justify certiorari.

A challenge to a transport permit order on grounds of mala fides or bias requires clear pleading and proof of a real disqualifying interest; mere suspicion or disagreement with the authority's appreciation of facts is insufficient. The Court noted that no personal, pecuniary, or official interest was specifically shown against the decision-maker, and that the Government was competent to examine whether subordinate transport authorities had acted illegally, irregularly, or improperly. Its differing view on the transfer of permits fell within its jurisdiction and discretion, and did not justify certiorari. The order was therefore not shown to be vitiated by bias, and no ground for judicial interference was made out.

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Issues: Whether the Government order granting the stage carriage permit to the respondent was vitiated by mala fides or bias, and whether the High Court could interfere with the order under Section 64-A of the Motor Vehicles Act.

Analysis: A challenge to an administrative or quasi-judicial order on the ground of bias requires clear pleading and proof of a real disqualifying interest, not merely circumstances that arouse suspicion. The allegations here did not specify any personal, pecuniary, or official interest on the part of the authority making the order. The Court held that the Government was competent to examine whether the subordinate transport authorities' orders were illegal, irregular, or improper, and that its differing view on the appellant's transfer of permits was a matter within its jurisdiction and discretion. Mere disagreement with the Government's appreciation of the facts or its construction of earlier policy orders did not furnish a ground for certiorari.

Conclusion: The order was not shown to be vitiated by mala fides or bias, and no ground for judicial interference was made out. The appeal therefore failed.

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