Reasoned closure of disciplinary complaints must be communicated to the complainant unless the statute excludes disclosure.

Under the Chartered Accountants disciplinary framework, a complaint closure decision must ordinarily be communicated with its reasons to the complainant. The statutory scheme in Sections 21 and 21A, read with the relevant Rules, was treated as requiring a reasoned closure order where the Director's prima facie view of no misconduct is accepted, and that reasoned decision must be conveyed unless disclosure is excluded by express provision or necessary implication. The court distinguished earlier rulings on personal hearing, holding that they did not control the separate issue of communication of reasons. The complainant was therefore entitled to receive the reasons supporting closure.

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Issues: Whether, upon closure of a complaint against a member under the Chartered Accountants disciplinary framework, the Board of Discipline was obliged to communicate the reasons for closure to the complainant.

Analysis: The statutory scheme under Section 21, Section 21A and the relevant Rules distinguishes between information and complaint, gives the complainant a fuller participatory role in a complaint-driven proceeding, and contemplates an order of closure where the Director's prima facie opinion of no misconduct is accepted. The requirement to pass an order of closure was read together with the obligation to communicate that order to the complainant. The Court held that reasons are an essential incident of a reasoned decision and, unless the statute expressly or by necessary implication excludes disclosure, the reasons must be conveyed to the affected complainant. Prior decisions declining a right of personal hearing were held not to govern the separate question of communication of reasons.

Conclusion: The complainant was entitled to be informed of the reasons for closure of the complaint, and the respondent's failure to communicate those reasons was impermissible.

Final Conclusion: The petition succeeded and the respondent was directed to furnish the reasons supporting the closure decision.

Ratio Decidendi: Where a statutory regime requires an administrative or disciplinary authority to record reasons for closure of a complaint, those reasons must ordinarily be communicated to the affected complainant unless excluded by express provision or necessary implication.

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