Natural justice requires consideration of binding precedent and reasons; refusal to entertain pre-deposit dispensation was set aside.

An appellate authority's refusal to entertain a request for dispensation of pre-deposit was held unsustainable because it failed to consider a material Supreme Court precedent and other relevant material relied on by the petitioner. The Bombay HC noted that the authority did not explain why the cited decision was inapplicable and recorded no reasons for distinguishing it. Such omission in quasi-judicial decision-making amounts to breach of natural justice. The impugned order was set aside, and the application for dispensation of pre-deposit was restored for fresh consideration in accordance with law.

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Issues: Whether the order of the appellate authority refusing to entertain the request for dispensation of pre-deposit was vitiated for failure to consider a material precedent and relevant material, and for absence of reasons.

Analysis: The authority had relied on a conclusion adverse to the petitioner without dealing with the Supreme Court decision on which the petitioner had placed reliance. It neither considered why the cited decision did not apply nor recorded reasons distinguishing it. A quasi-judicial authority cannot ignore material relevant to the decision-making process, and omission to consider such material amounts to violation of the principles of natural justice.

Conclusion: The impugned order was unsustainable and was set aside, and the application for dispensation of pre-deposit was restored for fresh consideration in accordance with law.

Ratio Decidendi: A quasi-judicial order is vitiated where relevant material and binding precedent relied upon by a party are not considered and no reasons are recorded for rejecting them.

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