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Issues involved: Constitutional validity of Rule 3 of the All India Services (Conditions of Service-residuary matters) Rules, 1960; Power of Central Government to review its earlier orders.
Constitutional Validity of Rule 3: The appellant challenged the Central Government's order on three grounds, including the contention that Rule 3 of the All India Services Rules was ultra vires as it conferred arbitrary power. The rule allows the Central Government to relax rules causing undue hardship, and the appellant argued it gave absolute discretion without objective standards. However, the court clarified that the rule aims to prevent undue hardship on civil servants and is guided by the public interest in efficiency and integrity. The court emphasized that the power to relax rules is to be exercised justly and equitably, not arbitrarily. Judicial review is applicable to ensure the power is used in the public interest. The court found Rule 3 constitutional, as it serves the purpose of ensuring efficiency and integrity in civil services. Power of Central Government to Review Orders: The appellant contended that the Central Government lacked the power to review its earlier orders as the rules did not explicitly grant such authority. Citing previous cases, the appellant argued that the power to review must be conferred by statute. However, the court differentiated between administrative and quasi-judicial decisions, stating that administrative decisions are subject to policy changes. Governments should have the flexibility to alter decisions in administrative matters without being bound by strict judicial procedures. The court emphasized that administrative decisions, when reviewed, remain subject to judicial review. Ultimately, the court dismissed the appeal, upholding the Central Government's authority to review its decisions in administrative matters.
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