Quasi-judicial authorities must pass reasoned and speaking orders to satisfy the principles of natural justice.

The Petitioner, a co-owner of land in Village Govindpur, challenged the order dated 22.07.2019 passed by the Collector (Respondent No. 2), which dismissed his revision against partition proceedings

Previously, a co-owner (Umadevi) obtained a partition order from the Tehsildar without impleading the Petitioner

That order was set aside by the Sub-Divisional Officer (SDO) on 04.04.2016, a decision upheld by the Board of Revenue

Despite this, Respondent No. 5 initiated fresh partition proceedings before the SDO, who constituted a committee for partition

The Petitioner filed a revision against these proceedings before the Collector, who dismissed it via the impugned order without assigning specific reasons or addressing the Petitioner's contentions regarding the finality of previous orders

1. Whether the impugned order dated 22.07.2019 passed by the Collector is unsustainable for being a non-speaking and unreasoned order

2. Whether the recording of reasons is a mandatory requirement for a quasi-judicial authority under the principles of natural justice

The Court primarily applied the principles of natural justice concerning the necessity of reasoned orders by quasi-judicial authorities

It relied on the landmark precedent Kranti Associates Private Limited v. Masood Ahmed Khan (2010) 9 SCC 496, which established that recording reasons is an essential component of natural justice, and the absence of such reasons renders a quasi-judicial or administrative order unsustainable

The Court found that the Collector’s order was "cryptic" and failed to demonstrate a proper application of mind

It noted that the revisional authority did not adjudicate the merits of the case or address the rival contentions, particularly the Petitioner's objections regarding the maintainability of fresh partition proceedings after earlier orders had attained finality up to the Board of Revenue

By applying the doctrine laid down in Kranti Associates, the Court reasoned that since the Collector acted as a quasi-judicial authority, the failure to provide a "speaking order" (an order disclosing the reasons for the decision) constituted a procedural illegality that violated the principles of natural justice

The Court remanded the matter to the Collector, District Datia, for fresh consideration

The Collector was directed to afford all parties a due opportunity of hearing and to pass a reasoned and speaking order strictly in accordance with the law

The parties were ordered to appear before the Collector on 13.05.2026

The Court clarified that it expressed no opinion on the merits of the underlying land dispute