Quasi-Judicial Authorities Must Record Independent Reasons to Satisfy Principles of Natural Justice.

The dispute arose from a civil suit regarding partnership property, where the matter was referred to arbitration.

Respondent Nos. 3 to 5 (Chartered Accountants) were appointed as Local Commissioners to undertake the rendition of accounts.

The petitioners, alleging deficiencies in the resulting rendition report, filed a complaint for professional misconduct with the Institute of Chartered Accountants of India (ICAI).

The Directorate (Discipline) formed a prima facie opinion that the respondents were not guilty.

Subsequently, the Board of Discipline issued a communication dated 19.10.2022, stating they "concurred with the reasons" of the Director and closed the complaint without providing independent reasoning.

The petitioners challenged this closure via a writ petition.

1. Whether the Board of Discipline is required to assign independent and speaking reasons when concurring with a prima facie opinion to close a misconduct complaint.

2. Whether the communication of a mere conclusion, without disclosing the process of reasoning, satisfies the principles of natural justice.

Section 21 of the Chartered Accountants Act, 1949, and Rule 9 of the Chartered Accountants (Procedure of Investigations of Professional and Other Misconduct and Conduct of Cases) Rules, 2007.

Trideep Raj Bhandari v. Institute of Chartered Accountants of India, establishing that "Order" includes the reasons for the decision and that complainants are entitled to these reasons.

Assistant Commissioner, Commercial Tax Department v. Shukla and Brothers, requiring a reasoned or speaking order as part of the principles of natural justice.

S.N. Mukherjee v. Union of India, which mandates recording reasons to exclude arbitrariness and ensure fairness in quasi-judicial functions.

The court found that the impugned communication was deficient because it recorded a conclusion (concurrence) without disclosing the "process of reasoning" that led to it.

Responding to the respondent's argument that reasons were available in the Director’s prima facie opinion or via RTI, the court held that the duty to assign reasons is an essential concomitant of natural justice that cannot be bypassed by requiring the complainant to seek information elsewhere.

By citing S.N. Mukherjee, the court reasoned that while reasons in an administrative/quasi-judicial order need not be as elaborate as a court judgment, they must be "clear and explicit" to indicate that the authority considered the points in controversy.

Since the Board failed to provide independent justification, the order was deemed arbitrary and incapable of proper judicial review.

The court allowed the petition, set aside the Impugned Orders dated 19.10.2022 and 24.06.2022, and remitted the matter back to the concerned authority for a fresh decision through a speaking order.