Administrative Law

Mineral Development Ltd. v. State of Bihar

AIR 1960 SC 468; (1960) 2 SCR 909

Citation: AIR 1960 SC 468; (1960) 2 SCR 909
Court: Supreme Court of India
Date: 15 December 1959
Bench: B.P. Sinha, CJ, K. Subba Rao, P.B. Gajendragadkar, K.C. Das Gupta and J.C. Shah, JJ.

Facts

Whether administrative action is invalid if influenced by personal bias or mala fides.

Administrative power must be exercised for the statutory purpose.
Personal hostility, political rivalry or private motive cannot influence the decision.
Bias may arise from personal interest, hostility or prior involvement.
Mala fide exercise of power is invalid.

The Court examined the surrounding circumstances, not merely the formal order.
Even if the order appears lawful on paper, courts can look at whether the power was used for an improper purpose.
The Minister’s personal hostility created serious doubt about impartiality.
Where the decision-maker is personally interested in harming the affected party, the decision cannot be treated as fair.
Administrative discretion is given for public purpose, not personal vendetta.
The Court therefore treated the action as vitiated by mala fides/bias.

The Supreme Court invalidated the action.
It held that administrative decisions affected by personal bias or mala fides cannot stand.
Use this case for: personal hostility of the authority can vitiate administrative action.