Judicial review examines administrative decision-making process, not the merits or correctness of the decision.

The 73 petitioners, claiming to be members of the Jajpur Road Truck Owners Association, challenged the order dated 13.05.2026 passed by the Additional District Magistrate, Kalinga Nagar, Jajpur Road, concerning disputes between the Jajpur Road Truck Owners Association and the Vyasanagar Truck Owners Association.

The dispute related, inter alia, to the non-renewal of vehicle registrations of members of the Vyasanagar Association in the register maintained by the Jajpur Road Association.

The Additional District Magistrate recorded that both associations were separately registered entities, directed them to function independently and peacefully with their respective registered members, held that members registered with the Vyasanagar Association need not have their vehicles renewed under the Jajpur Road Association, and directed the parties to approach the appropriate registering authority regarding alleged irregularities.

An earlier order dated 25.06.2026 had considered the petitioners’ submissions and questioned the maintainability and basis of the challenge; after a change in roster, the matter was assigned to the present Bench.

Whether the Additional District Magistrate’s order dated 13.05.2026, issued in the context of maintaining peace and tranquillity between two truck owners’ associations, was liable to be quashed under Article 226 of the Constitution.

Whether the High Court, in judicial review, could reassess the merits and reasons of the administrative decision as if exercising appellate jurisdiction.

Whether the petitioners’ grievance concerning their alleged formation of a trade union and consequent inability to re-register their vehicles could be adjudicated in the present writ petition.

The Court applied the scope of judicial review under Article 226 of the Constitution, emphasizing that judicial review examines the legality and fairness of the decision-making process rather than substituting the Court’s view for that of the competent administrative authority.

It relied on Bombay Intelligence Security (India) Ltd. v. Union of India, AIR 2022 Ori 197 : 2022 (III) ILR-CUT-34, which, drawing on Chief Constable of the North Wales Police v. Evans, held that judicial review is not an appeal on the merits and that the Court must ensure fair treatment and lawful exercise of power, without usurping the authority’s decision-making function.

The Court further applied the principle that an administrative authority’s satisfaction in a matter within its lawful domain cannot ordinarily be re-examined as an appellate court, particularly where the impugned action was directed towards maintaining public peace and tranquillity.

The Court held that the Additional District Magistrate was concerned primarily with regulating the functioning of two separately registered associations and preventing law-and-order problems, rather than finally determining the legal character or status of either association.

The directions requiring the associations to function independently, recognize their respective registered members, and maintain peace were viewed as administrative measures within the authority’s stated objective of preserving public tranquillity.

None of the challenged observations was found to impose an adverse adjudication against the petitioners; the reference to the alleged non-renewal of vehicle registrations was merely a recital of the grievance placed before the authority.

The petitioners’ separate contention regarding the formation of a trade union and denial of vehicle re-registration had not been the subject matter before the Additional District Magistrate and therefore could not furnish a basis for quashing the impugned order.

Applying the limited scope of judicial review, the Court declined to reassess the correctness of the administrative reasons as if hearing an appeal.

The Court upheld the impugned administrative order for the purposes of judicial review and declined to express any opinion on whether truck owners could form a trade union or accept membership among truck owners.

The petitioners were, however, left at liberty to pursue any other remedy available to them under law.