Reasoned decision-making in registration cancellation matters: non-speaking orders were quashed and remanded for fresh hearing.

A non-speaking cancellation of registration order was liable to be set aside where the record showed inconsistent findings on whether a reply had been filed, demonstrating lack of application of mind. The appellate order did not cure the defect because an adverse quasi-judicial decision affecting registration must disclose reasons and comply with fair hearing requirements. The Allahabad HC quashed both the original and appellate orders and remitted the matter for fresh adjudication after granting the petitioner an opportunity to be heard and to file a reply.

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Issues: Whether the cancellation of registration order and the appellate order were liable to be quashed for being non-speaking and passed without application of mind, and whether the matter required fresh adjudication after opportunity of hearing.

Analysis: The cancellation order recorded that a reply had been filed and simultaneously stated that no reply had been submitted, reflecting a clear lack of application of mind. The appellate order did not cure this defect. An adverse quasi-judicial order affecting registration must contain reasons and must satisfy the requirement of a fair hearing and reasoned decision-making.

Conclusion: The impugned original and appellate orders were quashed and the matter was remitted for fresh consideration after granting opportunity of hearing and permitting the petitioner to file a reply.

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