Governmental discretion in choosing a Mandal Headquarters is reviewable only for arbitrariness, mala fides, or irrelevant considerations.

The choice of a Mandal Headquarters under the Andhra Pradesh Districts (Formation) Act, 1974 was held to be a discretionary governmental function, with judicial review limited to illegality, arbitrariness, mala fides or extraneous considerations. The Court declined to substitute its own view of comparative suitability for the Government's assessment of administrative convenience and accessibility. Executive guidelines on headquarters selection were treated as non-statutory instructions, not enforceable rules, so their breach did not by itself justify mandamus absent recognised public law infirmity. The High Court, therefore, had no jurisdiction to reweigh the material and direct shifting of the headquarters to another place, and the Government's notifications were restored.

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Issues: (i) whether the location of a Mandal Headquarters under the Andhra Pradesh Districts (Formation) Act, 1974 was a governmental function not amenable to writ interference except on limited grounds; (ii) whether the executive guidelines governing the choice of Mandal Headquarters had statutory force and were enforceable in writ jurisdiction; (iii) whether the High Court could quash the Government's choice and direct shifting of the Mandal Headquarters to another place.

Issue (i): whether the location of a Mandal Headquarters under the Andhra Pradesh Districts (Formation) Act, 1974 was a governmental function not amenable to writ interference except on limited grounds

Analysis: The power to divide the State into districts, revenue divisions and mandals, and to finalise the location of a Mandal Headquarters, vested in the Government under the Act. The statutory scheme required publication of proposals and consideration of objections, but the ultimate choice of headquarters remained with the Government. The decision was to be made having regard to administrative convenience, accessibility and the object of bringing administration nearer to the people. Judicial review could extend to illegality, arbitrariness, mala fides or extraneous considerations, but not to substitution of the Court's own preference for that of the Government on comparative suitability.

Conclusion: The choice of Mandal Headquarters was a discretionary governmental function, and writ interference was not warranted merely because the Court considered another place preferable.

Issue (ii): whether the executive guidelines governing the choice of Mandal Headquarters had statutory force and were enforceable in writ jurisdiction

Analysis: The guidelines were issued as executive instructions to Collectors and were not framed as statutory rules under the Act. They were intended to guide proposals and were not published in the Official Gazette as binding law. A breach of such non-statutory instructions did not, by itself, create a legal right enforceable by mandamus. Relief could follow only if the action was shown to be arbitrary, discriminatory, or otherwise vitiated by recognised public law grounds. On the record, the Government had considered the proposals, objections and suggestions, and no mala fides or improper purpose was established.

Conclusion: The guidelines were not enforceable statutory commands, and their non-observance did not justify writ relief in the absence of arbitrariness or bad faith.

Issue (iii): whether the High Court could quash the Government's choice and direct shifting of the Mandal Headquarters to another place

Analysis: Even if a deviation from the guidelines could be examined, the proper course would have been, at most, to quash the notification and leave the matter for reconsideration by the Government. The High Court went beyond judicial review by reweighing marks, comparing village facilities, and directing that headquarters be shifted to a different place. That amounted to the Court assuming the Government's administrative function and issuing a mandamus to enforce executive guidelines lacking statutory force.

Conclusion: The High Court had no jurisdiction to direct shifting of the Mandal Headquarters to a particular place.

Final Conclusion: The notifications selecting the Mandal Headquarters stood restored, and the writ petitions challenging those selections failed.

Ratio Decidendi: Non-statutory executive guidelines governing an area of administrative discretion do not confer an enforceable legal right, and the Court cannot substitute its own view of comparative suitability for the Government's decision unless the action is shown to be arbitrary, mala fide, or based on irrelevant considerations.

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