Non-speaking adjudication orders are unsustainable when material submissions and cited case law are ignored, requiring remand for fresh decision.

An adjudication order that does not deal with the appellant's factual submissions or the case law cited in support is treated as a non-speaking order and is vulnerable on natural justice grounds. Where material contentions are ignored, the order lacks proper reasoning and cannot be sustained as a reasoned decision. The appropriate course in such circumstances is remand for fresh adjudication, with the lower authority required to consider the submissions and supporting authorities and decide the matter de novo in accordance with the principles of natural justice.

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Issues: Whether the adjudication order was vitiated for non-consideration of the appellant's submissions and cited case law, warranting remand for fresh decision after observing natural justice.

Analysis: The impugned order was passed without dealing with the appellant's factual submissions or the judicial authorities relied upon during adjudication. An order which ignores material submissions and supporting case law is defective and cannot be treated as a speaking order. In such circumstances, the merits of the dispute are not examined at the appellate stage, and the matter is sent back for fresh adjudication.

Conclusion: The order was held to be a non-speaking order and the matter was remanded to the lower authority for de novo adjudication after following the principles of natural justice.

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