Quasi-judicial orders failing to record cogent reasons are unsustainable and violate principles of natural justice.

The petitioner holds a valid 12-bore arms license (valid until 31.12.2027).

On 28.11.2024, the petitioner applied to respondent No. 2 for permission to sell his old, damaged weapon and replace it with a new non-prohibited (N.P.) arm.

Although an inquiry was conducted by the armourer via respondent No. 3, the resulting report was unclear. Consequently, respondent No. 2 rejected the application via an impugned order dated 01.05.2026.

The petitioner challenged this rejection on the grounds that it was a non-speaking order passed without application of mind.

1. Whether the respondent authority is legally obligated to record cogent reasons when rejecting an application for the replacement of a licensed firearm under the Arms Rules.

2. Whether the impugned order, passed without assigning reasons or considering relevant rules, violates the principles of natural justice.

Rules 18 and 80 of the Arms Rules, 2016, which govern the replacement of firearms for valid license holders.

Kranti Associates (P) Ltd. v. Masood Ahmed Khan (2010) 9 SCC 496, which established that recording reasons is an indispensable component of the decision-making process for judicial, quasi-judicial, and administrative authorities to ensure transparency, accountability, and the absence of arbitrariness.

The court observed that the petitioner possessed a valid arms license and was seeking a replacement for a damaged weapon as permitted by law.

Upon reviewing the record, the court found that the State counsel could not dispute that the impugned order was non-speaking.

Applying the principles from Kranti Associates, the court reasoned that "reasons are the heartbeat of orders" and that the failure of respondent No. 2 to assign any justification for the rejection rendered the decision arbitrary.

The court noted that administrative transparency is a "sine qua non" for preventing the abuse of power and that the authority failed to objectively consider relevant factors or the petitioner's grounds for replacement.

The High Court quashed the impugned order and remanded the matter back to the authorities for reconsideration. The respondents were directed to pass a reasoned order in accordance with the law, after giving the petitioner an audience, within 30 days of receiving the certified copy of the judgment.