Reviewing Authority exercising quasi-judicial powers must pass a reasoned and speaking order addressing all grounds raised.

The petitioner, while serving as Assistant Director of the Child Protection Unit in Muzaffarpur, was served a show-cause notice on June 4, 2018.

The notice alleged dereliction of duty for failing to report harassment and exploitation of girls at the Balika Grih (Remand Home) in his inspection reports, which were later uncovered in a social audit by the Tata Institute of Social Studies (TISS).

Subsequent departmental proceedings led to a punishment order dated March 20, 2020.

The petitioner filed a review petition against this order, which was subsequently rejected by the Reviewing Authority via order dated December 15, 2020.

The petitioner challenged both the original punishment and the review order before the High Court, contending that the review order was cryptic and failed to address the legal grounds raised.

1. Whether the Reviewing Authority, acting as a quasi-judicial body, is mandated to pass a reasoned and speaking order while disposing of a review petition.

2. Whether the impugned review order dated December 15, 2020, suffered from legal infirmity due to non-consideration of the specific points raised by the petitioner.

The court applied the fundamental principle of administrative law that a Reviewing Authority functions as a Quasi-Judicial Authority.

As such, the authority is legally obligated to pass a reasoned and speaking order that demonstrates the application of mind to three primary pillars of judicial review: violation of principles of natural justice, procedural lapses/irregularities, and the proportionality of the punishment.

The Court observed that while the petitioner had raised specific legal and factual grounds in his review petition—including procedural irregularities and the exorbitance of the punishment—the Reviewing Authority failed to address a single point.

The Court characterized the impugned order as "evasive" and "cryptic," noting that it lacked the necessary reasoning required of a quasi-judicial body.

The Court rejected the State's contention that the review was dismissed because no "reasonable point" was raised, finding instead that the lack of internal reasoning in the order itself constituted a failure to exercise jurisdiction properly.

It held that a quasi-judicial order must be reasoned, which was completely lacking in the present case.

The Reviewing Authority was directed to pass a fresh, reasoned, and speaking order after granting the petitioner an opportunity for a hearing.

The petitioner was directed to appear before the authority within 30 days, and the authority was ordered to conclude the proceedings within 90 days of the production of the court's order. The writ petition was accordingly disposed of.