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Issues:
Delegation of quasi-judicial powers by the Commissioner under the Madhya Pradesh Municipal Corporation Act, 1956. Analysis: The case involved petitions challenging property tax valuation made by a Municipal Corporation under the Madhya Pradesh Municipal Corporation Act, 1956. The petitioners objected to the valuation and contended that the Commissioner had no authority to delegate powers under Section 148 of the Act. The main issue was whether the power to determine objections to valuation under Section 148 could be delegated by the Commissioner to any officer of the Corporation as per Section 69(4) of the Act. The Supreme Court precedent established that judicial power cannot be delegated unless expressly permitted by law. The Court examined the relevant provisions of the Act, specifically Section 69(4), which empowers the Commissioner to delegate powers to any officer of the Corporation. It was argued that this provision only pertained to administrative powers, but the Court held that it enabled delegation of all powers conferred upon the Commissioner by the Act, including quasi-judicial powers. The Court referenced a Supreme Court decision to emphasize that control and superintendence in delegation of quasi-judicial functions do not imply intervention in decision-making but rather administrative control. The Court rejected the argument that the power to decide objections could not be delegated to an officer who participated in the valuation process, noting no evidence of bias. It clarified that the duty to make a provisional valuation and decide objections both rested with the Commissioner. The Court distinguished between objections hearing and appeals, stating that appeals were under the jurisdiction of the District Court. Ultimately, the petitions were dismissed, parties were to bear their own costs, and any security amount was to be refunded to the petitioners. Interim stay orders were also vacated.
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