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In Bandhua Mukti Morcha v. Union of India, , the Supreme Court laid down the underlying rationale for the appointment of Commissions for the purpose of gathering facts and data when there is a complaint relating to a breach of fundamental rights:

"The Supreme Court has evolved he practice of appointing Commissions for the purpose of gathering facts and data in regard to a complaint of breach of a fundamental rights made on behalf of the weaker sections of the society. The report of the Commissioner would furnish prima facie evidence of the facts and data gathered by the Commissioner and that is why the Supreme Court is careful to appoint a responsible person as Commissioner to make an enquiry or investigation into the facts relating to the complaint. It is interesting to note that in the past the Supreme Court has appointed sometimes a district magistrate, sometimes a district Judge, sometimes a professor of law, sometimes a journalist, sometimes an officer of the Court and sometimes an advocate practising in the Court, for the purpose of carrying out an enquiry or investigation and making report to the Court because the commissioner appointed by the Court must be a responsible person who enjoys the confidence of the Court and who is expected to carry out his assignment objectively and impartially without any predilection or prejudice."