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P.Shanthi vs The District Collector on 20 February, 2019

22.The learned Counsel for the petitioner asserted that notice should have been issued to the petitioner before a decision had been taken to withdraw the cheque signing authority. That contention was based not only on the principles of natural justice, but also on the dictum laid down, according to the learned Counsel for the petitioner, in 2011 (2) CTC 381, in the case of P.Suganthi vs The District Collector cum Inspector of Panchayat and another. In that case, the District Collector, who was the respondent therein, had passed an order transferring the cheque signing power of the appellant, who was the Panchayat President, to the Block Development Officer, pending an enquiry under Section 205 of the Tamil Nadu Panchayats Act, 1994. A Writ Petition was filed questioning transfer of such authority. The Writ Petition was dismissed. The petitioner therein took up the issue before the Division Bench on appeal. In the appeal, the Division Bench held as follows:
Madras High Court Cites 2 - Cited by 2 - S Manikumar - Full Document

Godde Venkateswara Rao vs Government Of Andhra Pradesh And Others on 11 October, 1965

Similarly, if the 18/29 https://www.mhc.tn.gov.in/judis W.P.(MD)No.20082 of 2021 quashing of the order which is in breach of natural justice is likely to result in revival of another order which is in itself illegal as in Gadde Venkateswara Rao vs. Government of Andhra Pradesh [1966 (2) SCR 172 = AIR 1966 SC 828], it is not necessary to quash the order merely because of violation of principles of natural justice.
Supreme Court of India Cites 7 - Cited by 537 - Full Document

S. L. Kapoor vs Jagmohan & Ors on 18 September, 1980

23.Chinnappa Reddy, J. in S.L.Kapoor's case [(1980) 4 SCC 379], laid two exceptions (at p.395) namely, " if upon admitted or indisputable facts only one conclusion was possible", then in such a case, the principle that breach of natural justice was in itself prejudice, would not apply. In other words if no other conclusion was possible on admitted or indisputable facts, it is not necessary to quash the order which was passed in violation of natural justice. Of course, this being an exception, great care must be taken in applying this exception.
Supreme Court of India Cites 26 - Cited by 1083 - O C Reddy - Full Document

K. L. Tripathi vs State Bank Of India And Others on 4 October, 1983

In K.L.Tripathi Vs. State Bank of India ( 1984(1) SCC 43), Sabyasachi Mukherji, J. (as he then was) also laid down the principle that not mere violation of natural justice but de facto prejudice (other than non-issue of notice) had to be proved. It was observed: quoting Wade Administrative Law, (5th Ed.PP.472-475) as follows: ( para 31) "....it is not possible to lay down rigid rules as to when principles of natural justice are to apply, nor as their scope and extent ....There must have been some real prejudice to the complainant; there is no such thing as a merely technical 19/29 https://www.mhc.tn.gov.in/judis W.P.(MD)No.20082 of 2021 infringement of natural justice. The requirements of natural justice must depend on the facts and circumstances of the case, the nature of the inquiry, the rules under which the tribunal is acting, the subject matter to be dealt with and so forth".
Supreme Court of India Cites 13 - Cited by 474 - S Mukharji - Full Document

Rajendra Singh vs The State Of Madhya Pradesh& Others on 8 August, 1996

25.The 'useless formality' theory, it must be noted, is an exception. Apart from the class of cases of "admitted or indisputable facts leading only to one conclusion" referred to above,- there has been considerable debate of the application of that theory in other cases. The divergent views expressed in regard to this theory have been elaborately considered by this Court in M.C. Mehta referred to above. This Court surveyed the views expressed in various judgments in England by Lord Reid, Lord Wilberforce, Lord Woolf, Lord Bingham, Megarry, J. and Straughton L.J. etc. in various cases and also views expressed by leading writers like Profs. Garner, Craig, De. Smith, Wade, D.H. Clark etc. Some of them have said that orders passed in violation must always be quashed for otherwise the Court will be prejudging the issue. Some others have said, that there is no such absolute rule and prejudice must be shown. Yet, some others have applied via-media rules. We do not think it necessary, in this case to go deeper into these issues. In the ultimate analysis, it may depend on the facts of a particular case.”
Supreme Court of India Cites 4 - Cited by 929 - B P Reddy - Full Document
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