Reward discretion must be exercised fairly; token awards without proper consideration can be quashed for arbitrariness.

A reward scheme conferring discretion on the authority must be exercised fairly, objectively and on relevant considerations. Where the informant's information had already been judicially found to have led to the seizure of contraband, a drastically reduced reward without proper consideration of the material factors was treated as a token award and not a genuine assessment of the claim. Such an exercise was held arbitrary and indicative of non-application of mind, making the decision liable to be quashed and reconsidered afresh.

---

---

Issues: Whether the reduced reward sanctioned to the informer was the result of a proper exercise of discretion, or whether it was arbitrary and liable to be quashed for non-application of mind.

Analysis: The reward scheme vested discretion in the authority, but that discretion had to be exercised fairly, objectively, reasonably, and with reference to all relevant circumstances. The information supplied by the petitioner had already been judicially found to be the information that led to the seizure of the contraband goods. In that background, the fact that the reward was reduced to a comparatively trifling amount, without proper consideration of the material factors bearing on the claim, showed that the authority had not genuinely applied its mind to the merits of the case. A token award in such circumstances was treated as a sham exercise of discretion rather than a lawful assessment of the claim.

Conclusion: The reduced reward was quashed for arbitrariness and non-application of mind, and the matter was directed to be reconsidered afresh.

Ratio Decidendi: A statutory or administrative discretion governing reward or similar benefits must be exercised reasonably, fairly, and on relevant considerations; if the authority awards a token amount without proper consideration of material factors, the decision is liable to be treated as no real exercise of discretion.

---