CLASSIFICATION OF ADMINISTRATIVE ACTION

A) INTRODUCTION

The phrase “administrative action” is broad and defies precise definition. The
administrative process, a by-product of today’s intensive style of administration, transcends the
traditional division of governmental authority and unifies all the functions that were previously
carried out by three distinct State organisations. Hence, there is a consensus among
administrative law writers that it is not only impossible but also pointless to attempt to categorise
administrative duties on any conceptual basis.

An administrative action is a legal action concerning the conduct of a public

administrative body. This kind of action can for example lead to the reversal of certain decisions
by public bodies or compel an authority to take a certain action.

Administrative acts are those that are carried out in accordance with administrative law,
which deals with the authority and responsibilities of administrative authorities. Legal actions
involving a public administrative body are referred to as administrative actions.

These actions defend the general populace and uphold social order. It is an action that is
neither judicial nor legislative in nature. Natural justice rules must always be followed when
exercising administrative authority, albeit they may vary based on the circumstances of each
instance. These actions compel authorities to act or not act.

Even then a student of administrative law is compelled to delve into the field of
classification because the present-day law, especially relating to judicial review, freely employs
conceptual classification of administrative action. Thus, speaking generally, an administrative
action can be classified into four categories:

(1) Rule-making action or quasi-legislative measures.

(2) Rule-decision action or quasi-judicial action.
(3) Rule-application action or administrative action.
(4) Ministerial action or pure administrative action.

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 B) NATURE, SCOPE AND SIGNIFICANCE OF ADMINISTRATIVE ACTIONS

The executive authorities that are carrying out their duties are not need to be entirely
administrative, quasi-judicial, or quasi-legislative in nature. The category of administrative
actions includes a wide range of operations. The administrative action is one that is neither
legislative nor judicial in nature. Legally binding administrative action might be either statutory
or non-statutory. The courts have the authority to stop such actions if they violate citizens' rights
or go against natural justice principles.

There are already too many cases pending in our courts, which burdens our judiciary.
Hence, the judiciary cannot address administrative issues concurrently. In order to lessen the
current burden on the judiciary, quasi-judicial and quasi-legislative bodies have been given
authority. Because the executive branch has the authority to address crises like war,
administrative action is always the best solution.

Administrative authorities have some powers that they effectively use for the benefit of
the citizens. These powers are effectively used through a variety of administrative acts.
Administrative decisions should adhere to fundamental fairness standards because if they don't,
they may be subject to judicial scrutiny.

Any natural person or corporation can challenge an administrative action in court, and the
courts can control these activities by issuing writs since the Supreme Court of India has the
authority to do so under Article 32 of the Indian Constitution.

C) CLASSIFICATION OF ADMINISTRATIVE ACTION

I) Rule-making action or quasi-legislative action

Any State's legislature is its primary legislative body. The legislature is given explicit
authority to make laws in some written constitutions, such as the US and Australian
Constitutions. The combined effect of Articles 107 to 111 and 196 to 201 in the Indian
Constitution, however, means that the law-making power can be exercised for the Union by
Parliament and for the States by the individual State Legislatures, even though this power is not
expressly bestowed in the legislature. This law-making authority must only be used by the bodies

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in whom it has been bestowed, according to the constitution's creators. But, in the twenty-first
century, these legislative bodies are unable to provide that quality and therefore, the delegation
of law-making power to the administration is a compulsive necessity. When any administrative
authority exercises the law-making power delegated to it by the legislature, it is known as the
rule-making action of the administration or quasi-legislative action.
The administration’s rule-making process exhibits all the traits that a typical legislative
process would. Generality, prospectivity, and a behaviour that grounds action on policy thought
and assigns a right or a disability are examples of such traits. There are some exceptions to these
characteristics. Administrative rule-making actions may occasionally be specific, retroactive, and
supported by evidence. A legislative action has four characteristics, according to Chinnappa
Reddy J. : 1) generality; 2) prospectivity; 3) public interest; and 4) rights and obligations flowing
from it. Elaborating the characteristics of a rule-making action of the administrative authority,
the Supreme Court in State of Punjab v. Tehal Singh' held that 1) where the provisions of a
statute provide for the legislative activity, i.e. making of a legislative instrument or promulgation
of a general rule of conduct or a declaration by a notification; 2) where the power exercised by
the authority under a statute does not concern the interest of an individual but relates to the
public in general, or concerns a general direction of a general character and is not directed
against an individual or to a particular situation; and 3) lays down a future course of action, such
action will generally held to be quasi-legislative action of the authority. Applying this test, the
court held that on making of a declaration determining the territorial area of a Gram Sabha and,
thereafter, establishing a Gram Sabha for that area is a quasi-legislative act of the administration.
It is on the basis of these characteristics that one can differentiate between quasi-
legislative and quasi-judicial action. A quasi-judicial action, as opposed to a quasi-legislative
action, is specifically based on the case’s circumstances and establishes an earlier right.
Unfortunately, it is not capable of simple distinction in other circumstances, such as wage or rate
setting. The Supreme Court left open the issue of whether the Working Journalists and Other
Newspaper Workers (Conditions of Service) and Miscellaneous Provisions Act, 1955’s Wage
Commission’s role is quasi-judicial or quasi-legislative in Express Newspaper (P) Ltd. V. Union
of India. Nonetheless, it was believed that giving the government the authority to set the price of
tax sugar constituted a form of quasi-legislation. This suggests that it is impossible and difficult
in theory to distinguish between legislative and administrative tasks. A quasi-judicial action, as

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opposed to a quasi-legislative action, is specifically based on the case’s circumstances and
establishes an earlier right. Unfortunately, it is not capable of simple distinction in other
circumstances, such as wage or rate setting. The Supreme Court left open the issue of whether
the Working Journalists and Other Newspaper Workers (Conditions of Service) and
Miscellaneous Provisions Act, 1955’s Wage Commission’s role is quasi-judicial or quasi-
legislative in Express Newspaper (P) Ltd. V. Union of India. Nonetheless, it was believed that
giving the government the authority to set the price of tax sugar constituted a form of quasi-
legislation. This suggests that it is impossible and difficult in theory to distinguish between
legislative and administrative tasks.
In the same manner, the Committee on Ministers' Powers which was appointed in
England in 1928 distinguished between administrative and quasi-legislative action on the ground
that where the former is a pro- cess of performing particular acts or of making decisions
involving the application of general rules to particular cases, the latter is the process of
formulating a general rule of conduct without reference to particular cases and usually for future
operation.
Though the rules of natural justice do not apply to legislative actions, yet reasonableness
and fair play in action must be observed as Article 14 of the Constitution equally applies to
legislative actions. Administrative rule-making action is controlled by Parliament and the courts.

II) Rule-decision action or quasi-judicial action

Today, administrative agencies with adjudicatory powers make the majority of
judgements that have an impact on a private individual instead of courts. The cause appears to be
that the traditional court system cannot provide the people with the quantity and quality of justice
required in a welfare state because administrative decision-making is also a by-product of the
intensive style of government. The phrase "quasi-judicial" is used in some jurisdictions to
describe administrative, adjudicative, or decision-making processes. Yet, the phrase "quasi-
judicial" is becoming less popular because it is ambiguous and challenging to define. Thus, it is
strictly avoided to use this word. Making decisions on an administrative level is described as
having the authority to carry out administrative tasks that also happen to require other tasks.
(1) Disciplinary proceedings against students.”

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 (2) Disciplinary proceedings against an employee for misconduct,
(3) Confiscation of goods under the Sea Customs Act, 1878.
(4) Cancellation, suspension, revocation or refusal to renew licence or permit by licensing
authority.
(5) Determination of citizenship.
(6) Determination of statutory disputes.
(7) Power to continue the detention or seizure of goods beyond a particular period.
(8) Refusal to grant “no objection certificate” under the Bombay Cinemas (Regulations) Act,
1953.
(9) Forfeiture of pensions and gratuity.
(10) Authority granting or refusing permission for retrenchment.
(11) Grant of permit by regional transport authority.
(12) Registration of a political party by the Election Commission.

 Attributes of administrative decision-making action or quasi-judicial action and the

distinction between judicial, quasi-judicial and administrative action

The Donoughmore Committee on Ministers’ Powers examined what makes a “true

judicial decision” and listed the attributes, depending on whether they were present or not, that
designated a decision as administrative or quasi-judicial. According to the Committee, a
legitimate judicial decision requires four conditions in addition to a lawsuit between two or more
parties. They are as follows:
(1) Presentation of the case.
(2) Ascertainment of questions of fact by means of evidence given by the parties.
(3) Ascertainment of questions of law on the basis of submission of legal arguments.
(4) A decision which disposes of the whole matter by applying the law to the facts.

A quasi-judicial decision involves the first two determinants, may or may not involve the
third, but never involves the fourth determinant, because the place of the fourth determinant is in

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fact taken by administrative action, the character of which is determined by the Minister’s free
choice involving expediency, discretion and policy considerations.

Administrative decisions are entirely different from quasi-judicial and judicial rulings in
their legal status. Administrative decisions are not required by law to take into account and
weigh arguments and submissions, gather evidence, or resolve any issues. The authority has
complete discretion over the reasons for taking action as well as the process for doing so.

The Committee’s strategy appears flawed since judges cannot be viewed as mere norm-
producing slot machines; rather, they weigh policy, socioeconomic and political philosophy,
experience, and discretion when making decisions. As litigation, just like legislation and
administration, is a stage in the accommodation of interests, it is widely acknowledged in the
twenty-first century that the court is like any other arm of the government. On the other hand, in
some administrative adjudication areas, such as tax, the administration adapts the law to the facts
in a similar way to how judges occasionally do. Consequently, it is incorrect to imply that the
vir- gin purity of a judicial decision is immediately diminished by the introduction of any policy.

The American “position-of-the-judge” approach is not an exception, just as the English

“law and policy” factor lacks adequate categorisation. According to the American system, a
court is a place where a judge preside as an arbitrator who has no stake in the dispute between
the parties. The institution and presentation are the responsibilities of the parties. On the other
hand, the judge in an administrative decision is rarely one who is disinterested in the matter and
sits detached like a judge. This classification matrix might be argued, and rightfully so, to be
inapplicable to independent tribunals where the presiding officer sits in judge-like detachment.

Therefore, only that classification determinant can be reasonable which is institutional

rather than functional. There are administrative agencies exercising adjudicatory powers which
are like full courts-it is only through the legislature’s decision that these are not categorised as
courts.

Yet, this does not imply that red and blue cannot be distinguished because purple is a
confusing mixture of the two colours. The elaborate judicial procedure is not required for
administrative decision-making; it suffices if, in the absence of any statutory requirements, the
decision is made by adhering to the minimum natural justice method.

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 There was a time when the view prevailed that the rules of natural justice have
application to a quasi-judicial proceeding as distinguished from an administrative proceeding.
The distinguishing feature of a quasi-judicial proceeding in this behalf is that the authority
concerned is required by law under which it is functioning to act judicially. Duty to act judicially
was spelt out in R. v. Electricity Commissioners by Lord Atkins thus:

Whenever any body of persons having legal authority to determine questions affecting
the rights of the subjects, and having the duty to act judicially, acts in excess of its legal
authority, they are subject to the controlling jurisdiction of the King’s Bench Division.

Lord Hewart CJ in R.v. Legislative Committee of the Church Assembly, ex p Haynes

Smith read this observation of Lord Atkin's comment to suggest that the obligation to behave
impartially should be a requirement separate from the "power to decide problems affecting the
rights of subjects"—something added to it. According to Krishna Iyer J, this gloss put forth by
The Hewart CJ on Lord Atkins LJ's dicta plagued the law for a protracted period of time and
stifled the development of the doctrine of natural justice. The court concluded that the duty to
behave impartially need not be introduced and that it can be determined from the nature of the
authority granted and how it is used and impact on the rights of the person affected. The court
was constrained in every case that came up before it to make a search for the duty to act
judicially, sometimes from tenuous material and sometimes in the cervices of a statute, and this
led to oversubtlety and over-refinement resulting in confusion and uncertainty in the law.

In India, the judicial search for the duty to act in good faith was sometimes made within
the parameters of the statute under which the authority exercised power and other times in the
hazy, distant, and extraneous, such as lis inter partes including proposition and opposition,
implications arising from the nature of the functions, and the rights affected thereby.

In addition to making the law ambiguous and confusing, this doctrinal approach of the
courts in India and England frequently prevented justice from being served. Ridge v. Baldwin
(Ridge), however, marked a turning point for England as Lord Reid noted that The Hewart’s
gloss was based on a misinterpretation of Lord Atkins’ findings. According to Lord Reid:

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 If Lord Heward meant that it is never enough that a body has a duty to determine what
the rights of the individual should be, but that there must always be something more to
impose on it a duty to act judicially, then that appears to me impossible to reconcile with
the earlier authorities.

According to Lord Reid, the obligation to act impartially must be inherent in the task at
hand and need not be demonstrated to be superior. Krishna Iyer J quoted Prof. Clark from his ar-
ticle, "Natural Justice: Substance and Shadow", who is of the view that the observation of Lord
Reid has restored light to an area "benighted by the narrow conceptualism of the previous
decade".

This development of law is traceable in India also where the Supreme Court even earlier
than Ridge was of the view that if there is power to decide and determine to the prejudice of a
person, the duty to act judicially is implicit in the exercise of such power. In fact, the foundation
of applying natural justice in administrative actions had been laid down in the dissent of Subba
Rao J in Radheyshyam Khare v. State of M.P. It is significant to note that he held:

…incompetency carries a stigma with it and what is more derogatory to the reputation of
the members of the Committee than to be stigmatised as incompetent to discharge their
statutory duties? Would it be reasonable to assume that public men in a democratic
country are allowed to be condemned unheard?

In the case of A.K. Kraipak v. Union of India, this dissension was strikingly pronounced
(Kraipak). The Supreme Court ruled in this case that even while choosing candidates for
government jobs is an administrative process, the selection committee has a responsibility to
operate legally. The court noted that the line separating an administrative power from a quasi-
judicial power is extremely slender and is slowly vanishing. Regard must be given to the
following when deciding whether a power is quasi-judicial or administrative:1) the nature of the
power conferred; 2) the authority on whom the power is conferred; 3) frameworth of the law
conferring that power; 4) the consequences ensuing from the exercise of that power; and 5) the
manner in which that power is expected to be exercised. In D.K. Yadav v. J.M.A. Industries Ltd.,
the Supreme Court further observed that the distinction between quasi-judicial and
administrative action which had become thin is now totally eclipsed and obliterated. Proceeding
a step further the Supreme Court clearly held in Chandra Bhavan Boarding and Lodging

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Bangalore v. State of Mysore that it is not necessary to classify an action of the administrative
authority as quasi-judicial or administrative because the administrative authority is bound to
follow the principles of natural justice in any case. In this case, the question was whether the
power to fix a minimum wage under the Minimum Wages Act, 1948 is quasi-judicial or
administrative.

The Supreme Court again outlined the characteristics of a quasi-judicial function in

Indian National Congress (I) v. Institute of Social Welfare. In this instance, the issue was: Is the
Election Commission’s role in registering political parties administrative or quasi-judicial? The
court held that the following conditions must be met for a statutory authority’s action to qualify
as a quasi-judicial act: 1) the authority is empowered by a statute to take any action; 2) the action
would negatively affect the subject; 3) there are no opposing parties and the dispute is between
the authority and the subject; and 4) the authority is required to act judicially by the statute the
said authority will be quasi-judicial. The court further elaborated that where the law requires that
an authority before arriving at a decision must make an enquiry, such a requirement of law
makes the authority quasi-judicial authority. In other words, if an authority is required to act
according to rules, its functions will be quasi-judicial. Therefore, if the authority has power to
summon witnesses, enforce their attendance, examine them on oath and requires discovery and
production of documents, its functions will be quasi-judicial.

Elaborating the law further, the court identified three characteristics of a quasi-judicial
action:

(1) It is in substance a determination upon investigation of a question by the application of

objective standards to facts found in the light of pre-existing legal rules;
(2) It declares rights or imposes upon parties obligations affecting their civil rights; and
(3) That the investigation is subject to certain procedural attributes considering the opportunity
to present its case to a party, the ascertainment of facts through the use of evidence if the
dispute is over questions of fact; and if the dispute is over questions of law, the presentation
of legal argument; and a decision resulting in the disposal of the matter on findings based
upon those questions of law and fact.

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 Applying the above characteristics, the court concluded in Manju Varma v. State of U.P.4
that the power exercised by the Chief Justice of the Allahabad High Court under paragraph 14 of
the United Provinces High Courts (Amalgamation) Order, 1948 to transfer a writ petition from
Lucknow Bench to Allahabad Bench in administrative capacity is quasi-judicial power subject to
review by the higher forum. The court observed that the Chief Justice could not have allowed the
plea without hearing the affected party and without determining on objective criteria and upon
investigation whether the case is transferable and should be transferred. The decision of the
Chief Justice would have direct bearing on the right of the appellant to choose “forum
convenience”, hence the action is quasi-judicial subject to review by the higher forum.

III) Rule-application action or administrative action.

Although the line between quasi-judicial from administrative action has blurred, it does
not negate the existence of either line. Even if two people are wearing the same coat, that does
not mean that they are the same. Although the distinction between quasi-judicial and
administrative action may no longer have much practical significance, it may nevertheless be
important for deciding the level of natural justice that should be applied in a particular
circumstance.

In Kraipak, the court held that one must consider the nature of the power granted, the
person to whom it is granted, the context within which it is granted, and the consequences in
order to establish whether the activity of the administrative authority is quasi-judicial or
administrative. In State of A.P. v. S.M.K. Parasurama Gurukul’s, the court determined that the
appointment of trustees by the government under Section 15 of the A.P. Charitable and Hindu
Religious Institutions and Endowments Act, 1966, is an administrative function rather than a
quasi-judicial one. The court also established that if there is a dispute between the parties and the
decision must be based on objective satisfaction, the action is quasi-judicial; otherwise, it is
administrative in the court came to the conclusion that since there is nothing in the Act to show
that the Collector has to act judicially or in conformity with the recognised judicial norms, and as
there is also nothing requiring the Collector to determine questions affecting the rights of any
party, the function of the Collector in giving or withholding permission of transfer of land to a
non-agriculturist under Section 63(1) of the Bombay Tenancy and Agricultural Lands Act, 1947

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is administrative. The Delhi High Court applying the same parameters held that the function of
the Company Law Board granting authority to shareholders to file a petition in the High Court is
an administrative and not a quasi-judicial function. Moving forward in the same direction, The
Supreme Court further held that Articles 10, 12(5), and 11-A of the Constitution give the
government the authority to refer cases to the Industrial Tribunals and to grant or deny licences
are of an administrative nature. In some cases, an administrative authority may even decide
factual issues before making a judgement that could impact someone’s rights, but even in those
circumstances, the role will still be considered administrative. In a similar way, if the purpose of
the authority is administrative and is determined by policy and expediency.

Administrative action is therefore a residual action that falls outside of the legislative and
judicial realms. It lacks generality and is solely focused on how to handle a specific
circumstance. It has no procedural obligations of collecting evidence and weighing argument. It
is based on subjective satisfaction where decision is based on policy and expediency. It does not
decide a right though it may affect a right. However, it does not mean that the principles of
natural justice can be ignored completely when the authority is exercising "administrative
powers". Unless the statute provides otherwise, a minimum of the principles of natural justice
must always be observed depending on the fact situation of each case. This mandate to adhere to
at least some natural justice principles places a responsibility on the administration to act justly
when conducting “administrative action.”

No comprehensive list of such actions may be drawn, however a few can be mentioned for
clarity’s sake:
(1) Issuing directions to subordinate officers not having the force of law.
(2) Making a reference to a tribunal for adjudication under the Industrial Disputes Act, 1947.
(3) Internment, externment and deportation.
(4) Granting or withholding sanction to file a suit under Section 55(2) of the Muslim Wakf
Act, 1954.
(5) Granting or withholding sanction by the Advocate General under Section 92 of the Civil
Procedure Code, 1908.
(6) Fact-finding action.
(7) Requisition, acquisition and allotment.

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 (8) Entering names in the surveillance register of the police.
(9) Power of the Chancellor under the U.P. State Universities Act, 1973 to take decision on
the recommendation of the selection committee in case of disagreement of the executive
council with such recommendation.
(10) Functions of a selection committee.
(11) Decision to extend time for anti-dumping investigation.

Administrative action may be statutory, having the force of law, or non-statutory, devoid
of such legal force. The bulk of the administrative action is statutory because a statute or the
Constitution gives it a legal force, but in some cases it may be non-statutory, such as issuing
directions to subordinates not having the force of law, but its violation may be visited with
disciplinary action. Though by and large administrative action is discretionary and is based on
subjective satisfaction, however, the administrative authority must act fairly, impartially and
reasonably.

IV) Ministerial or pure administrative action

A further distillate of administrative action is ministerial action. Ministerial action is that

action of the administrative agency which is taken as a matter of duty imposed upon it by the law
devoid of any discretion or judgment. Therefore, a ministerial action involves the performance of
a definite duty in respect of which there is no choice. Collection of revenue may be one such
ministerial action. Furthermore, if the statute requires that the agency shall open a bank account
in a particular bank or shall prepare the annual report to be placed on the table of the Minister,
such actions of opening of the bank account and the preparation of the annual report shall be
classified as ministerial. However, the area of such action is highly limited because any efficient
discharge of a governmental function presupposes at least some discretion vested in the
administrative authority. Gordon classifies the functions of administrative authorities into
judicial and non-judicial. Judicial functions involved the decision of rights and liabilities so that
an investigation and application of fixed legal standards was a material part of the functions.
Non-judicial functions are further divided into administrative and ministerial functions.
Ministerial functions are exercised by taking active, often coercive measures, and administrative

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functions by meting out policy and expediency with unfettered discretion. When an
administrative agency is acting ministerially, it has no power to consult its own wishes, but when
it is acting administratively its standards are subjective and it follows its own wishes.

D) CASE LAWS
1) A. K. Kraipak v. Union of India, (1969) 2 SCC 262: AIR 1970 SC 150.

Facts: In this case, there was an advertisement for a government post which was posted
by the government for the post of chief conservative of forest. Many candidates here in
applied including the acting chief conservative forest. When the interview was finally
conducted the judgement panel who are conducting the interview also included the acting
chief conservative officer.

There was another candidate A.K. Kraipak, he later on filed a case saying that the
justice is not being done because the acting chief conservative officer was also present in
the panel therefore it created a sort of biasness against the other candidates and the
selections are violative of Article 14 and 16 of the constitution of India and the selections
in question are dissipated by the contravention of the principles of natural justice.

The chief conservative officer contended that he was not in the panel when his
interview was being conducted. The Hon’ble court found the power exercised by the
selection board as an administrative one and tested the validity of the selections on that
basis.

Held: That the selections made by the selection committee were in violation of principles
of natural justice. Assistant Conservators have been selected for the senior scale service.
At the same time some of the officers who had put in more than eight years of service had
been selected for the junior scale service.

Hence it is not possible to separate the two sets of officers. For the reasons
mentioned above these petitions are allowed and the impugned selections set aside. The
Union Government and the State Government shall pay the costs of the petitioners.

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2) Karnataka Public Service vs B.M. Vijaya Shankar And Ors. 1992 AIR 952, 1992 SCR (1)
668
Facts: The Karnataka Public Service Commission conducted competitive examinations
for the state civil services and general instructions were given to the candidates that the
roll number should be written only on the front page of the answer sheet in the space
given for it and not anywhere else inside the answer sheet.
It was also cleared that the candidates must abide by the instructions and violation
of the instructions will make them liable to expulsion from examination or such other
punishment as the commission may deem fit. But one candidate violated the instructions
by enter his roll number on every page of the answer sheet and then the commission
cancelled his paper.
The candidate challenged the action of the commission before the Karnataka
administrative tribunal which directed the commission to get his answer sheet evaluated
by holding that no penalty was provided for breach of the instructions and the failure to
afford any opportunity to the candidate to explain his bonafide and innocence was
arbitrary. Against the decision of the tribunal the commission and the state filed this
appeal in this court.

Held: In the result, this appeal succeed and are allowed. The order passed by the tribunal
is set aside. The claim petition filed by the candidates shall stand dismissed because the
court said that this is purely an administrative action.

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 E) CONCLUSION
Most authors, attorneys, and jurists agree that any attempt to categorise or rank
administrative duties on a philosophical or speculative basis is pointless. To categorise activities
generally into administrative, quasi-legislative, quasi-judicial and ministerial categories is
necessary from time to time for administrative lawyers or administrative law students.

As these concepts cannot be applied in the form of closed and divided caskets, such
categories are therefore solely academic in character and have no influence on their application.

F) REFERENCES

 Webliography
https://lawbhoomi.com/ blog name: Administrative Actions: Meaning, Nature, Scope and
Significance by Nikhil Jain (Delhi Metropolitan Education, GGSIPU)

https://legalreadings.com/ Blog name: Classification of Administrative Action – An

Academic Overview by Khushboo Garg.

https://indiankanoon.org/

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