Whether Judicial interference is warranted when statutory authorities follow due process

Facts:
The case involves the cancellation of Booth Site No. 14, Sector 46-C, Chandigarh, sold to Manjit Kumar Gulati and others through an auction in 1989. The allottees failed to pay 75% of the remaining premium despite multiple notices and hearings. Their lease was canceled in 1991. Appeals and petitions filed by them and an alleged tenant, M/s. Mohit Medicos, were dismissed by statutory authorities. However, the High Court allowed the writ petitions, quashing the cancellation and ordering restoration of the site.

Contentions of the Appellant:
The Chandigarh Administration argued that the High Court erred in quashing the lease cancellation despite the allottees’ continuous defaults and non-compliance with payment terms. They claimed the allottees were given adequate opportunities but failed to clear dues. They further contended that M/s. Mohit Medicos lacked legal standing as no tenancy agreement existed.

Contentions of the Respondent:
The respondents, including the alleged tenant M/s. Mohit Medicos, argued that they were protected under tenancy laws and claimed to have occupancy rights. They contended that the authorities did not follow due process in canceling the lease and failed to serve the required notices.

Issues:
  1. Whether the cancellation of the lease of Booth Site No. 14 was legally justified.
  2. Whether M/s. Mohit Medicos had legal standing to challenge the lease cancellation.
  3. Whether the High Court erred in interfering with the statutory orders passed by the authorities.

Observations/Findings by the Supreme Court:
The Supreme Court found that the allottees had repeatedly failed to comply with payment obligations despite sufficient opportunities. The alleged tenant failed to provide any legal proof of tenancy. The Court held that the High Court wrongly intervened by entertaining writ petitions without valid grounds.

Principle of the Case:
The Court reaffirmed that judicial interference is unwarranted when statutory authorities follow due process. Only legally recognized parties with clear evidence of rights have the standing to challenge administrative decisions.

Final Order:
The Supreme Court allowed the appeals, setting aside the High Court’s order. It upheld the cancellation of the lease due to non-compliance by the allottees and dismissed the proxy litigation by M/s. Mohit Medicos.

Impact on Public Law and Order:
The judgment strengthens administrative efficiency by reducing frivolous litigation and ensuring compliance with lease terms. It emphasizes that judicial intervention is limited when authorities adhere to legal procedures, promoting trust in public administration.

Case Citation:
Supreme Court of India, Chandigarh Administrator & Others vs. Manjit Kumar Gulati & Others, Civil Appeal Nos. 14151-14152 of 2024 (arising out of SLP (C) Nos. 2283-2284 of 2016), Judgment dated December 10, 2024

 

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