Pranav Shukla
On 5th April, 2023, the Supreme Court of India in the case of Madhyamam Broadcasting Limited v. Union of India reinforced the constitutional importance of ‘Principle of Natural Justice’ under Articles 14, 19, and 21 of the Indian Constitution. The judgment draws on the principles established in the landmark decision of Maneka Gandhi v. Union of India , reiterating the intrinsic value of procedural fairness and its adaptability to contemporary challenges.
The Principle of Natural Justice is a fundamental concept in administrative and legal processes that ensures fairness in decision-making. It is rooted in the idea of ensuring that individuals receive a fair and unbiased hearing before any adverse decision is made against them. There are three core principles:
- Nemo judex in causa sua (No one should be a judge in their own case)
- Audi alteram partem (Hear the other side)
- Reasoned Decision: Decisions should be based on evidence and reasoning..
These principles aim to promote fairness, transparency, and accountability in legal and administrative proceedings.
The case raised critical questions regarding the inherent requirement of procedural fairness under the ‘Principle of Natural Justice’, the extent to which this principle can adapt without compromising their core essence, and the necessity of procedural safeguards like notice, inquiry reports, and a fair hearing in administrative actions. These issues focus on balancing the flexibility of natural justice with its fundamental guarantee of ensuring fairness and reasonableness.
The Court emphasized that procedural fairness is a constitutional mandate, serving as an inherent value and a requirement independent of the case outcome, thus, ensuring individuals a reasonable and fair process before any administrative or judicial action. It reaffirmed that the ‘Principle of Natural Justice’ are deeply rooted in Articles 14, 19, and 21 of the Constitution, and any deviation from this principle must meet the tests of reasonableness and fairness. Drawing extensively from the Maneka Gandhi judgment, the Court highlighted procedural fairness as an independent value and stressed the adaptability of natural justice principles to cater to varying circumstances while preserving their core objective of fairness..
Case Title: Madhyamam Broadcasting Limited v. Union of India
Case Citation: 2023 SCC Online SC 366
Bench: Dr.DY Chandrachud, CJ and Hima Kohli.
Click here to access the judgement.