Administrative orders must contain cogent reasons and address claims of parity to satisfy natural justice.

The Petitioner exported notified goods under Chapter 7A of the Foreign Trade Policy (FTP) 2015-2020 for two quarters: July–September 2019 and October–December 2019.

The Petitioner attempted to file online applications for Transportation and Marketing Assistance (TMA) for both periods, generating E-com reference numbers, but could not complete fee payments due to technical glitches on the DGFT portal.

By the time payments were successful, the portal prevented submission, citing expiry of the time limit.

The Competent Committee rejected the condonation of delay request on 07.04.2022 as being "without any merit".

A subsequent Review Committee maintained the rejection on 02.12.2022 without addressing the Petitioner’s contention that similarly situated companies had been granted relaxation.

The Petitioner challenged these decisions via a Writ of Certiorari.

Whether the Impugned Decisions (MOM dated 07.04.2022 and 02.12.2022) were arbitrary and violative of Article 14 for failing to provide reasoned findings and for ignoring claims of parity with similarly situated entities.

Whether administrative orders passed by statutory functionaries must be supported by reasons recorded within the order itself.

The Court applied the fundamental principle of administrative law that statutory and public authorities must pass reasoned orders.

It relied heavily on the precedent of Mohinder Singh Gill v. Chief Election Commr. (1978) 1 SCC 405, which establishes that the validity of a statutory order must be judged solely by the reasons mentioned therein and cannot be supplemented by fresh reasons in the shape of affidavits or subsequent explanations.

The Court also referenced Paragraph 2.59 of the FTP 2015-2020 regarding the right to a personal hearing.

The Court observed that the minutes of the meeting dated 07.04.2022 merely recorded the Petitioner’s case and rejected it without assigning any cogent reason for its lack of merit.

Regarding the Review Committee's decision dated 02.12.2022, the Court found that although a personal hearing was granted, the committee failed to deliberate upon or address the Petitioner’s specific argument regarding "identical matters" where other firms (e.g., M/s. Astish Industries) were granted relief.

Applying the Mohinder Singh Gill doctrine, the Court held that public orders must be construed objectively based on the language used in the order itself.

Because the impugned minutes lacked discernible reasoning and failed to address the grievance of discrimination, they were found to be legally unsustainable.

Consequently, the Court remitted the matter to the Review Committee for fresh consideration.

The Review Committee was directed to reconsider the case and pass a well-reasoned order within a reasonable timeframe.

the writ petition was disposed of with these directions.