Administrative orders passed mechanically by considering facts of a third party are liable to be quashed.

The petitioner, a Lecturer (LB), sought a transfer from the ‘T’ cadre to the ‘E’ cadre following the absorption of his services in July 2018

After his initial representations remained unanswered, the petitioner filed WPS No. 10059 of 2019, where the High Court of Chhattisgarh directed the Director of Public Instructions to decide on his representation

On 27.11.2020, the Director issued an order rejecting the request

The petitioner challenged this order on the grounds that while the preamble identified him, the substantive analysis and final determination in the order focused entirely on the claims of a third party, Pradeep Kumar Sahu

1. Whether the impugned order dated 27.11.2020 was passed in a mechanical manner without due application of mind to the petitioner’s specific case

2. Whether an administrative order addressing the facts of a third party instead of the claimant is legally sustainable

The Court emphasized the necessity for administrative authorities to properly consider representations and avoid passing mechanical orders

It specifically relied on the legal principles established by the Hon’ble Supreme Court in Union Public Service Commission v. Bibhu Prasad Sarangi and Others (2021) 4 SCC 516, which underscores the requirement for authorities to apply their minds to the specific facts of a case during the decision-making process

The Court observed that although the impugned order identified the petitioner in its opening paragraph, paragraph 5 of the same order proceeded to discuss and decide the claim of an unrelated individual, Pradeep Kumar Sahu

The Court found that the authority concerned failed to carry out a factual inquiry or provide a determination relevant to the petitioner's specific grievance regarding his cadre allocation

By substituting the petitioner's facts with those of a third party, the authority rendered a "mechanical" decision that failed to satisfy the Court's previous direction in WPS No. 10059 of 2019

Consequently, the Court held that the lack of due application of mind necessitated the quashing of the order

It granted the petitioner liberty to file a fresh representation before the Director, Directorate of Public Instruction. The Court directed the Director to re-consider the representation in light of the judgment in Union Public Service Commission v. Bibhu Prasad Sarangi (2021) 4 SCC 516 and pass a reasoned order

The petition was disposed of accordingly