Authority must recall a non-compliant order and pass a reasoned order after affording effective hearing.

The petitioners, a women’s self-help group and its Secretary, challenged the order dated 15 July 2026 passed by the Sub-Divisional Officer (Revenue), Sarangarh, in E-court Case No. 202606320600012/B-121/2025-26, titled State of Chhattisgarh v. President, Vrindawati Mahila Swa Sahayata Samuh Sankra.

Pursuant to the High Court’s earlier order dated 4 August 2026, the concerned Sub-Divisional Officer filed an affidavit explaining the circumstances in which the impugned order had been passed.

The respondents stated that the order dated 15 July 2026 would be recalled and that a fresh order would be passed in strict compliance with the High Court’s directions dated 14 July 2026 in WPC No. 3654 of 2026.

Whether the order dated 15 July 2026 was liable to be recalled because it was not passed in compliance with the High Court’s earlier directions and principles of fair hearing.

Whether the concerned Sub-Divisional Officer was required to provide the petitioners an effective opportunity of hearing and pass a fresh, reasoned and speaking order in accordance with law.

The Court applied the principles of natural justice, particularly the requirement of affording a fair and effective opportunity of hearing before taking an adverse administrative or quasi-judicial decision.

It further applied the requirement that an adjudicatory order must be reasoned and speaking, and that subordinate authorities must strictly comply with binding directions issued by the High Court.

No specific statutory provision or judicial precedent was cited in the order.

The Court considered the explanation furnished by the Sub-Divisional Officer and found it unsatisfactory and unacceptable.

However, since the respondents expressly undertook to recall the impugned order and pass a fresh order in compliance with the earlier directions, and since the petitioners’ principal grievance concerned the order dated 15 July 2026, the Court treated the undertaking as sufficient to dispose of the petition.

To safeguard procedural fairness and ensure adherence to the Court’s prior directions, it mandated an effective hearing, a fresh reasoned and speaking order, and strict compliance with the order dated 14 July 2026 in WPC No. 3654 of 2026.

The concerned Sub-Divisional Officer (Revenue) was directed to recall the order dated 15 July 2026 and pass a fresh, reasoned and speaking order strictly in accordance with law, after granting the petitioners a due and effective opportunity of hearing and complying with the High Court’s order dated 14 July 2026 in letter and spirit.

The Court warned that any future non-compliance with its directions could result in appropriate adverse or punitive action against the concerned officer in accordance with law.