[1] Overview [2] Concept of Natural Justice [3] Principles of Natural Justice [4] Speaking orders or Reasoned Decisions [5] Exception to the Principle of Natural Justice [6] Doctrine of Post Decisional Hearing [7] Case Law and Judgements
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[1] Overview
1.1 Natural Justice: Natural Justice in simple terms can be defined as the minimum standards or principles which the administrative authorities should follow in deciding matters which have the civil consequences.
1.2 Natural Justice represents higher procedural principles developed by judges which every administrative agency must follow in taking any decision adversely affecting the rights of a private individual.
1.3 One of the cardinal principles of the administrative law is that any action which has civil consequences for any person cannot be taken without complying with the Principles of Natural Justice.
1.4 The Principles of Natural Justice are firmly grounded under various Articles of the Constitution. There are mainly two principles of Natural Justice – (a) Rule against Bias & (b) Rule of Fair Hearing.
[2] Concept of Natural Justice
2.1 Natural Justice is a concept of Common Law and it is the Common Law which is the counterpart of the American concept of procedural due process. Natural Justice implies – fairness, reasonableness, equity and equality.
2.2 The concept of doctrine of Principles of natural Justice and its application in justice delivery system is since the beginning of justice delivery system.
2.3 Natural Justice represents higher procedural principles developed by judges which every administrative agency must follow in taking any decision adversely affecting the rights of a private individual.
2.4 Natural Justice is an expression of English common law which involves a procedural requirement of fairness.
2.5 The term Natural Justice signifies basic principles of justice which are made available to everyone litigant during trial.
2.6 Historical background & development: Natural Justice is not a creation of Constitution or mankind; it is originated along with human history and civilization. The Greeks accepted the principle that no one should be condemned unheard. It was first applied in ‘Garden of Eden’ where opportunity to be heard was given to Adam and then he was punished.
2.7 Principles of Natural Justice are also found in (a) Arthsastra written by Kautailya; (b) Manusmriti and many different texts as well.
2.8 Before the beginning of era of Christ, Aristotle spoke about Principles of Natural Justice and called it as universal law.
2.9 Legal evolution: The birth of the Principle of Natural Justice cannot be ascertained in single time frame as it took its shape and necessity during the course human civilization. But, the Principles of Natural Justice through various decisions of courts can easily be ascertained through their application in a given situation may depend on multifarious factor. Hon. Supreme Court many times in its judgement talked about natural justice.
2.10 In the case of Mohinder Singh Gill Vs Chief Election Commissioner, Hon. Apex Court upheld that Natural Justice is a pervasive facet of secular law where spiritual touch enlighten litigation, administration and adjudication to make fairness a creed of life.
2.11 Hon. Supreme Court in the case of Swadeshi Cotton Mills Vs Union of India observed that Natural Justice is a branch of public law and is a formidable weapon which can be wielded to secure justice to the citizen.
2.12 In another judgement in the case of Canara Bank Vs V K Awasthi, Hon. Supreme Court observed that Principles of Natural Justice are those rules which have been laid down by courts as being the minimum protection of rights of individual against the arbitrary procedure that may be adopted by a judicial, quasi-judicial and administrative authority while making those order affecting those rights.
2.13 Constitutional provision: The Principles of Natural Justice are firmly grounded under various Articles of the Constitution. All fairness which is included in the principles of Natural justice can be read into Article 21 of the Constitution.
2.14 Article 14 applies not only to discriminatory class legislation but also to arbitrary or discriminatory State action. When a person is deprived of his/her life and personel liberty.
2.15 Violation of Natural Justice results in arbitration, therefore, violation of natural Justice is violation of Equality Clause of Article 14. As a result now, the principle of natural justice cannot be wholly disregarded by law because this would violate the fundamental rights guaranteed by Article 14 and 21 of the Constitution.
[3] Principles of Natural Justice
3.1 Principles of Natural Justice are those rules which have been laid down by courts as being minimum protection of the rights of the individual against the arbitrary procedure that may be adopted by a judicial, quisi-judicial and administrative authority while making an order affecting those rights.
3.2 Norms of Natural Justice: Norms of Natural Justice are as follows:
(a) No one should be condemned unheard;
(b) No one shall be judge in one’s own case;
(c) A party is entitled to know the reasons for the decision;
(d) Making available a copy of statutory report.
3.3 Principles of Natural Justice: There are mainly two Principles of Natural Justice and these two principles are – (A) Nemo Judex in Causa Sua (Rule Against Bias) & (B) Audi Alteram Partem (Rule of Fair Hearing).
3.4 (A) Nemo Judex in Causa Sua (Rule Against Bias): Nemo Judex in Causa Sua is a Latin word which means “No man shall be a judge in his own cause”. It means the deciding authority must be impartial and without bias. It implies that no man can act as a judge for a cause in which he has some interest which may be pecuniary or otherwise.
3.5 Bias: Bias means an operative prejudice, whether conscious or unconscious, in relation to a party or issue. As a result of this, the ‘Rule Against Bias’ strikes against those factors which may improperly influence a judge in arriving out at a decision in any particular case.
3.4 The requirement of this principle is that the judge must be impartial and must decide the case objectively on the basis of evidence on record and merit. Therefore, if a person for whatever the reason, cannot take an objective decision on the basis of evidence on record and on merit he/she shall be said to be biased.
3.5 A person cannot take an objective decision in a case in which he/she has an interest for, as human psychology tells that, very rarely can people take decisions against their own interests. This rule of disqualification is applied not only to avoid the possibility of a partial decision but also to ensure public confidence in the impartiality of the administrative adjudicatory process because not only must “no man be judge in his/her own cause” but also “justice should not only be done but should manifestly and undoubtedly be seen to be done”.
3.6 On the basis of above, it is clear that Rule Against Bias is so important in Principles of Natural Justice and it is required to be discussed in length. There are many kind of ‘Bias’ under this principle. Primely important ‘Bias’ components are discussed in successive paras hereinafter.
3.7 Personal Bias: It arises from a certain relationship equation between the deciding authorities and the parties which results into inclination of him/her unfavourably or otherwise on the side of one of the parties. Such equation may develop out of varied form of personal or professional hostility or friendship.
3.8 An example of Personal Bias can be taken from a judgement delivered by Hon. Apex Court that it quashed the selection list prepared by Departmental Promotion Committee (DPC) which considered the confidential reports of candidates prepared by an officer who himself was a candidate for promotion. In this case, Principle of Natural Justice – Rule against Bias (Personal Bias) was not followed.
3.9 Pecuniary Bias: The kind of favour/bias which involves financial interest and decision is affected is known as Pecuniary Bias. Judicial approach is a unanimous and decisive on the on the point that any financial interest whether small or huge would vitiate administrative as well as judicial action. Pecuniary Biased member cannot be involved in any decision-making machinery as chances of fair and impartial decision may not be delivered.
3.10 In a case, Hon. Supreme Court quashed the decision of the Textbook Selection Committee because some of its members were also authors of books which were considered for selection.
3.11 Subject Matter Bias: Those cases fall within this category where the deciding authority is directly, or indirectly or otherwise, involved in the subject matter of the case. Mere involvement would not vitiate the administrative action unless there is a real likelihood of bias.
3.12 In a case, Hon. Supreme Court quashed the decision of the Andhra Pradesh Government, nationalizing road transport on the ground that the Secretary of the Transport Department who gave hearing was interested in the subject-matter.
3.13 Departmental bias or Instrumental bias: It when the functions of a Judge and the Prosecutor (Public Prosecutor/Government counsel) are combined in the same department as it is not uncommon to find that the same department which initiates the matter also decides, department which heard and decided the case was the same, the element of departmental bias vitiated administrative action.
3.14 The problem of departmental bias is something which is inherent in the administrative process, and if it is not effectively checked, it may negate the very concept of fairness in the administrative proceeding.
3.15 In a case, Hon. Supreme Court quashed the notification of the Government which conferred powers of a Deputy Superintendent of Police on the General Manager, Haryana Roadways in matters of inspection of vehicles on the ground of departmental bias. In this case, private bus operators alleged that the General Manager of Haryana Roadways who is a rival in business in the State, cannot be expected to discharge his duties in a fair and reasonable manner he would be too lenient in inspecting the vehicles belonging to his own department.
3.16 Preconceived Notion Bias: This type of bias is also known as unconscious bias. All person exercising adjudicatory powers are humans with human prejudices, no matter some persons are more humans than others. This may include class bias and personality bias. Every person is a product of a class and inherits some characteristics of the class which may also reflect in his decision-making process. In the same manner, the personality of every person is a combination of his biological and social heredity which determine his values and attitudes in a way that may condition his/her decision-making process. In general, it can be said community-based bias.
3.17 The problem of Preconceived Notion Bias is such which is inherent in any adjudication and cannot be eliminated unless detected by some over action of the authority and also is so detected can vitiate an administrative hearing if it has a direct relation with decision. This may include a situation where the deciding officer openly expresses his/her prejudice.
3.18 Bias on Account of Obstinacy: It is a new category of bias as discovered by Hon. Supreme Court arising out of thoroughly unreasonable obstinacy. It literally means unreasonable and unwavering persistence and the deciding officer would not take no for an answer. This category of bias was discovered in a situation where a judge of Hon. Calcutta high Court upheld its own judgement while sitting in appeal against its own judgement.
3.19 (B) Audi Alteram Partem (Rule of Fair Hearing): Rule of fair hearing simply implies that a person must be given an opportunity to defend himself/herself as it is not merely of some importance but is of fundamental importance that justice should not be done but should manifestly and undoubtedly be seem to be done. However, refusal to participate in enquiry without valid reason cannot be pleaded as violation of natural justice at a later state.
3.20 The important components of this rule are – (a) Right to Notice; (b) Right to present case & evidence; (c) Right to Rebut Adverse Evidence; (d) Cross-Examination; (e) Legal Representation; (f) Report of Inquiry to be shown to the Other Party; (g) Post Decisional Hearing. These components of Rule of Fair Hearing are discussed in length in successive paras hereinafter.
3.21 Right to Notice: The term Notice originated from a latin word notitia means being known. ‘Notice’ is the starting point of any hearing in the case. Unless a person knows the formulation of subjects and issues involved in the case, he/she cannot defend himself/herself. It is not enough that the notice in the case be given, but it must be adequate also. Any decision taken without serving notice is liable to be quashed subject to conditions.
3.22 Notice which is to be served in the case is to be adequate and must contain – (i) sufficient information and material so as to enable the person concerned to put up an effective defence; (b) name of person to whom notice to be served; (c) Time, place & nature of hearing; (d) sufficient time to be given to comply with the requirement of notice; (e) Statement of specific charges which the person has to meet/alleged as a person cannot be punished for any other charge for which notice is not served. A notice should not create any dilapidated condition in the case.
3.23 Right to Present Case & Evidence: The adjudicatory authority should extend reasonable opportunity to the party to present his/her case. This can be done through writing or orally at the discretion of the authority unless the statute under which the authority is functioning directs or otherwise.
3.24 The requirements of natural justice are met only if opportunity to represent is given in view of the proposed action. The demands of natural justice are not met even if the very person proceeded against has been furnished information on which the action is based, if it is furnished in a casual way or for some other purposes. This does not mean that the opportunity need be a “double opportunity”, that is one opportunity on the factual allegations and another on the proposed penalty.
3.25 This can be done through writing or orally. Oral hearing is not an integral part of fair hearing unless the circumstances are so exceptional that without oral hearing a person cannot put up an effective defence. In a case where complex legal and technical questions are involved or where stakes are very high, oral hearing shall become a part of fair hearing. Thus, in the absence of a statutory requirement for oral hearing courts will decide the matter taking into consideration the facts and circumstances of every case.
3.26 Right to Rebut Adverse Evidence: The right to rebut adverse evidence presupposes that the person is informed about the evidence against him. This does not, however, necessitate the supply of adverse material in original in all cases. It is sufficient if the summary of the contents of the adverse material in made available provided it is not misleading.
3.27 The opportunity to rebut evidence necessarily involves the consideration of two factors: (i) Cross-Examination and (ii) Legal representation.
3.28 Cross-Examination: Cross-Examination is the most powerful weapon to elicit and establish truth. In case, where the witnesses have orally deposed, the refusal to allow cross-examination would certainly amount to violation of the principles of natural justice. In the area of labour relations and disciplinary proceedings against civil servants also, the right to cross-examination is included in the rule of fair hearing.
3.29 Legal Representation: Normally, representation through a lawyer in any administrative proceeding is not considered an indispensable part of the rule of natural justice as oral hearing is not included in the meaning of fair hearing. Denial of legal representation is justified on the ground that lawyers tend to complicate matters, prolong the proceedings and destroy the essential informality of the proceedings.
3.30 It is further justified on the ground that the representation through a lawyer of choice would give edge to the rich over the poor who cannot afford a good lawyer. The fact Techniques of Law remains that unless some kind of a legal aid is provided by the agency itself, the denial of legal representation would be a mistaken kindness to the poor people.
3.31 It is required to be established to what extent legal representation would be allowed in administrative proceedings depends on the provisions of the Statute. Factory Laws do not permit legal representation, Industrial Dispute Acts allows it with the permission of the Tribunal and some Statutes like Income Tax Act permit legal representation as a matter of right. However, the Courts in India have held that in situations where the person is illiterate, or the matter is complicated and technical, or expert evidence is on record or a question of law is involved, or the person is facing a trained prosecutor, some professional assistance must be given to the party to make his/her right to defend himself/herself correctly.
3.32 Report of Inquiry to be shown to the Other Party: It is experiences in many cases, especially in matters relating to disciplinary proceedings, on the basis of the report of the inquiry submitted by the Inquiry Officer, suitable action is taken by the competent authority. Under these circumstances a very natural question arises whether the copy of the report of the inquiry officer be supplied to the Charged Officer (DGS) before final decision is taken by the competent authority or otherwise? This question is important both from the constitutional and administrative law point of view.
3.33 One of the cardinal principles of the administrative law is that, any action which has civil consequences for any person cannot be taken without complying with the Principles of Natural Justice. Therefore, administrative law practice in disciplinary matter has always been whether failure to supply the copy of the Report of the Inquiry Officer to the Charged Officer (DGS) before final decision is taken by the competent authority would violate the principles of natural justice or otherwise?
3.34 In the same manner the constitutional question subsequently arises in such a situation, whether failure to supply the copy of the report of the Inquiry Officer to the Charged Officer (DGS) would violate the provisions of Article – 311(2) of the Constitution of India? Article – 311(2) of the Constitution provides that no government employee can be dismissed or removed or reduced in rank without giving him/her a reasonable opportunity of being heard in respect of charges framed against him/her. Therefore, it has always been a perplexing question whether failure to supply the report of the inquiry officer to the DGS before final decision is taken would amount to failure to provide “reasonable opportunity” as required under Article 311(2).
3.35 In the same line of interpretation, there is a question arises if copy of Inquiry Officer is not supplied to the DGS be treated as violation of Article 14 of the Constitution which enshrines the great harmonizing and rationalizing principle or otherwise?
3.36 Neither the findings nor the recommendations of the Inquiry Officer are binding on the Disciplinary Authority in disciplinary proceeding. The findings of Inquiry Officer with evidence recorded constitute material on which the government has ultimately to act and this is the only purpose of the Inquiry. Hence, it is advisable to show the findings of Inquiry officer to the DGS to satisfy the norm – reasonable opportunity under Principle of natural Justice.
3.37 The application of the principles of natural justice varies from case to case depending upon the factual aspect of the matter. For example, in the matters relating to major punishment, the requirement is very strict and full-fledged opportunity is envisaged under the statutory rules before a person is dismissed removed or reduced in rank, but where it relates to only minor punishment, a mere explanation submitted by the DGS concerned meets the requirement of principles of natural justice. Also, in some matters oral hearing may be necessary but in others, It may not be necessary.
[4] Speaking orders or Reasoned Decisions
4.1 It is important to discuss other related principles of natural justice which was developed during the course of time. The third principle of Natural Justice which has developed in course of time is that the order which is delivered affecting the rights of an individual must be a speaking order.
4.2 This is necessary with a view to exclude the possibility of arbitrariness in the action. A bald order requiring no reason to support it, may be passed in an arbitrary and irresponsible manner. It is a step in furtherance of achieving the end where society is governed by Rule of Law.
4.3 The other aspect of the matter is that the party, against whom an order is passed, in fair play, must know the reasons of passing such order. It has a right to know the reasons. The orders against which appeals are provided must be speaking orders. Otherwise, the aggrieved party will not be in a position to demonstrate before the appellate authority as to in which manner, the order passed by the initial authorities is bad or suffers from illegality.
4.4 To a very great extent, in such matters bald orders render the remedy of appeal nugatory. However, it is true that administrative authorities or Tribunals are not supposed to pass detailed orders as passed by the courts of law. They may not be very detailed and lengthy orders but they must at least show that the mind was applied and for the reasons, howsoever briefly they may be stated, the order by which a party aggrieved is passed.
4.5 There cannot be any prescribed form in which the order may be passed but the minimum requirement as indicated above has to be complied with. Hon. Supreme Court has many times taken the view that non-speaking order amounts to depriving a party of a Right to Appeal. It has also been held in some of the decisions that the appellate authority, while reversing the order must assign reasons for reversal of the findings.
[5] Exception to the Rule of Natural Justice
5.1 Any decision whether it is judicial, quasi-judicial or any kind are delivered considering Principles of Natural Justice. But there are some circumstances when the principles of Natural Justice can be excluded either expressly or by necessary implication subject to the provisions of Article 14 and 21 of the Constitution.
5.2 If the Statue, expressly or by necessary implication, precludes the rules of natural justice, it will not suffer invalidation on the ground of arbitrariness. Exceptions are discussed in successive paras hereinafter.
5.3 Exclusion in Emergency: In exceptional cases of emergency, where prompt preventive or remedial action is needed, the requirement of notice and hearing may be obviated. For example, in situations where a dangerous building is to be demolished, or a company has to be wound up to save depositors, Principles of Natural Justice may be excluded in such cases.
5.4 However, the administrative determination of an emergency situation calling for the exclusion of rules of natural justice is not final. The courts may review the determination of such a situation. Natural Justice is pragmatically flexible and is amenable to capsulation under compulsive pressure of circumstances. In this context, Hon. Supreme Court observed: “Natural Justice must be confined within their proper limits and must not be allowed to run wild”.
5.6 Exclusion in Cases of Confidentiality: The observance of Principle of Natural Justice may be excluded in case of confidentiality in a situation when there is a possibility of ends of justice being defeated instead of being served. For example: In a case, Hon. Supreme Court held that the maintenance of surveillance register by the police is a confidential document. Hence, neither the person whose name is entered in the register nor any other member of public can have access to it.
5.7 Exclusion in case of routine matters: Subject to circumstances aroused in a specific case in routine matter, exclusion of Principles of Natural Justice is applied on it. For Example: In a case, the Examination Commission cancelled the examination of the candidate because, in violation of rules, the candidate wrote his roll Number on every page of the answer sheet. In this case, Hon. Supreme Court held that the principles of natural Justice are not attracted as the rule of hearing is strictly construed in academic discipline as if this is ignored it will not only be against public interest but would also erode social sense of fairness.
5.8 In another example, A student of the university was removed from the rolls for unsatisfactory academic performance without giving any pre-decisional hearing. Hon. Supreme Court held that the very nature of academic adjudication appears to negative in right of an opportunity to be heard. Therefore, if the competent academic authorities examine and assess the work of a student over a period of time and declare his work unsatisfactory, the rules of natural justice may be excluded as the principle of natural justice has been followed since the process of assessment of his performance.
5.9 Exclusion based on Impracticability: Principles of Natural Justice may be excluded on the grounds of administrative impracticability. For example: In a case where the entire M.B.A. entrance examination was cancelled by the University due to mass copying, the court held that notice and hearing to all the candidates is not possible in this situation, which has assumed national proportions. Therefore, the court sanctified the exclusion of the rules of natural justice on the ground of administrative impracticability.
5.10 Exclusion in cases of Interim Preventive Action: If the action of the administrative authority is a suspension order in the nature of a preventive action and not a final order, the application of the principles of natural justice may be excluded. Exclusion of the Principles of Natural Justice is also applicable when a candidate is debarred from entering the premises of the institution and from attending classes till the pendency of a criminal case against him for stabbing a co-student. In this case, court found that this is the same case of suspension of an employee hence Principles of Natural Justice are excluded.
5.11 Exclusion in cases of Legislative Action: Action taken by Legislative, may be plenary or subordinate, and is not subjected to the Principles of Natural Justice because these rules lay down a policy without reference to a particular individual. Legislative action has mass impact. On the same logic principles of natural justice can also be excluded by a provision of the Constitution also. Constitution of India excludes the Principles of Natural Justice in Articles 22, 31(A), (B), (C) and 311(2) as a matter of policy as they not only imply on an individual. It has mass impact.
5.12 Nevertheless, if the legislative action is arbitrary, unreasonable and unfair, courts may quash such a provision under Articles 14 and 21 of the Constitution. In a case, Hon. Supreme Court held that no principles of natural justice have been violated when the government issued notification fixing the prices of certain drugs. The Court reasoned that since notification flowed from a legislative act and not an administrative one so the principles of natural justice do not apply.
5.13 Exclusion Where No Right of Person is Infringed: In case, where no right has been conferred on a person by any statute or any such right arises from common law, the Principles of Natural Justice are not applicable. This can be illustrated by referring a decision of Hon. Supreme Court in a case where, The Delhi Rent Control Act makes provision for the creation of limited tenancies. Sections 21 and 37 of the Act provide for the termination of limited tenancies. Combined effect of these sections is that after the expiry of the term a limited tenancy can be terminated. Hon. Supreme Court held that after the expiry of the prescribed period of any limited tenancy, a person has no right to stay in possession and hence no right of his is prejudicially affected which may warrant the application of the principles of natural justice.
5.14 Exclusion in case of Statutory Exception or necessity: In case of statutory exception or necessity, the Principles of Natural Justice may not be applicable as disqualification on the ground of bias against a person will not be applicable if he is the only person competent or authorized to decide that matter or take that action. If this exception is not allowed there would be no other means for deciding that matter and the whole administration would come to a grinding halt. In such case, the necessity must be genuine and real. Therefore, the doctrine of necessity cannot be invoked where the members of the Text Book Selection Committee were themselves the authors because the constitution of the selection committee could have been changed very easily by the Government.
5.15 Exclusion in case of Contractual Arrangement: In case of contractual agreement the principles of Natural Justice may be excluded as terms and conditions are already mentioned in the contractual agreement and the same is well known to the individual. This may be referred in a judgment delivered by Hon. Apex court in case, it was held that, the Principles of Natural Justice are not attracted in case of termination of an arrangement in any contractual field. Termination of an arrangement/agreement is neither a quasi-judicial nor an administrative act so that the duty to act judicially is not attracted.
[6] Doctrine of Post Decisional Hearing
6.1 Post Decisional hearing: Post decisional hearing is a hearing which takes after a provisional decision is reached not in case of final decision. It takes place where it may nt be feasible to hold pre-decisional hearing. The idea of Post-Decisional Hearing is developed to maintain a balance between administrative efficiency and fairness to individuals.
6.2 In Post-Decisional Hearing, an individual is given an opportunity to be heard after a tentative decision has been taken by the authorities. In certain situations, it is not feasible for the authorities to have a normal pre-decisional hearing and decision are being taken on first instance before providing the individual to present his case. In such case, it would be considered reasonable if the authorities provide Post Decisional Hearing in compliance with the Principles of Natural Justice.
6.3 Post-Decisional Hearing affords an opportunity to the aggrieved person to be heard. However, post-decisional hearing should be an exception rather than being the rule itself. It is acceptable in the following situations:
(a) Where the original decision does not cause any prejudice or detriment to the person affected;
(b) Where there is urgent need for prompt action; and
(c) Where it is impracticable to afford pre-decisional hearing.
6.4 The idea of Post-Decisional Hearing has been developed to maintain a balance between administrative efficiency and fairness to the individual. This harmonizing tool was developed by Hon. Supreme Court in a case Maneka Gandhi v. Union of India. In this case on 1st June, 1976 the passport of the petitioner, a journalist, was impounded in public interest by an order of the Government without furnishing any reasons therefore. The petitioner, being aggrieved by such arbitrary action of the Government, filed a petition before the Supreme Court under Article-32 challenging the validity of the impoundment order.
6.5 One of the contentions of the Government Techniques of Law was that the rule of Audi Alteram Partem must be held to be excluded because it may frustrate the very purpose of impounding the passport. Rejecting the contention, the court rightly held that though the impoundment of the passport is an administrative action yet the rule of fair hearing is attracted by necessary implication and it would not be fair to exclude the application of this cardinal rule on the ground of administrative convenience. Though the court had not quashed the order outrightly but has developed the technique of Post Decisional Hearing in order to balance such situations to provide a fair opportunity of being heard immediately after serving the order impounding the passport which would satisfy the mandate of natural justice.
[7] Case Law and Judgements
7.1 Coming soon.