Withdrawal of substantive certificates creating third-party rights without prior show-cause notice violates principles of natural justice.

The Petitioner, an MSME, was issued a Development Order Certificate on 12.12.2023 and an Amended Certificate on 13.08.2024 by Respondent No. 1 (OIL) following the supply of control line products.

Based on complaints regarding the Petitioner's manufacturing capabilities and indigenous development claims, OIL conducted an inspection on 04.01.2026.

Consequently, OIL issued a communication on 15.01.2026 placing the certificates in abeyance pending internal verification and a related proceeding in the Delhi High Court.

After the Petitioner submitted a representation as directed by the Bombay High Court in a separate challenge, Respondent No. 1 issued a "Speaking Order" on 04.03.2026, unilaterally withdrawing the Development Order Certificates entirely.

1. Whether the Respondent No.1 could legally withdraw the Development Order Certificates, which created vested rights, without issuing a prior show-cause notice.

2. Whether the Speaking Order dated 04.03.2026 violated the principles of natural justice and Article 21 of the Constitution of India.

Principles of Natural Justice (Audi Alteram Partem), which are considered a facet of Article 14 and Article 21 of the Constitution of India.

An administrative authority cannot take away rights accrued to a party or pass an adverse order without informing the noticee of the specific allegations and providing a reasonable opportunity to be heard.

The court observed that the Development Order Certificates functioned as completion certificates, creating credentials that allowed the Petitioner to secure further contracts.

While the court declined to interfere with the initial 'abeyance' order dated 15.01.2026 (as the Bombay High Court had already seized the matter), it found the subsequent withdrawal of the certificates via the Speaking Order dated 04.03.2026 to be procedurally flawed.

The court reasoned that Respondent No. 1 exceeded its mandate; instead of merely deciding on the representation regarding the suspension, it permanently revoked the certificates without a formal show-cause notice.

The court held that until a noticee is informed of the specific allegations (fraud or lack of indigenous manufacturing), they cannot meaningfully defend their rights.

The court directed Respondent No. 1 to issue a detailed show-cause notice within 10 days, provide the Petitioner 15 days to reply, and grant a personal hearing before passing a fresh order within two months.

The petition was disposed of with no order as to costs.