Mandatory time limits in CHA revocation proceedings were breached, making the licence revocation unsustainable and set aside.

Time limits prescribed in the CHA licensing regulations for initiation and completion of revocation proceedings are mandatory, not directory. Where the licence was first suspended, followed by notice and inquiry, but the final revocation order was passed after an unexplained and inordinate delay, the statutory disciplinary scheme was held to be frustrated and serious prejudice caused to the licence holder. The revocation order was therefore unsustainable for breach of the mandatory time schedule and was set aside.

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Issues: Whether the order revoking the CHA licence was liable to be set aside for non-compliance with the time limits prescribed for initiation and completion of proceedings under the licensing regulations.

Analysis: The proceedings for revocation were initiated after suspension of the licence, followed by a show cause notice and inquiry, but the final revocation order was passed after a long and unexplained delay. The governing regulations prescribe a time-bound procedure for disciplinary action against a CHA, and judicial precedent treated those limits as mandatory rather than directory. Inordinate delay in completing the proceedings defeats the statutory scheme and causes serious prejudice to the licensee.

Conclusion: The revocation order was unsustainable for breach of the mandatory time schedule and was set aside.

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