Question

The real test of ‘duty to act judicially ‘ to distinguish a quasi judicial authority from an administrative authority was finally settled in the historical decision

• A. Ridge v Baldwin
• B. Dwarka Nath v ITO
• C. Nakkuda Ali v M.F.De S. Jayaratne
• D. Province of Bombay v Khushaldas Advani

Hint:

*Ridge v. Baldwin* is regarded as the Magna Carta of modern natural justice.
It established that whenever a public authority makes a decision affecting a person's rights or livelihood, they must give that person a fair hearing first.

Answer 1

The Correct Option is A

Step 1: Understanding the Question:
The question asks to identify the landmark decision that settled the test for a "duty to act judicially" as the key distinction between a quasi-judicial authority and an administrative authority.

Step 2: Key Legal Principles and Approach:
Historically, courts held that the principles of natural justice (such as a fair hearing) applied only to judicial or quasi-judicial bodies, not to administrative bodies.
For a body to be quasi-judicial, it was argued that there must be a specific "duty to act judicially" superadded by the statute itself.

Step 3: Detailed Explanation:

• The Old Restrictive Approach: In cases like Nakkuda Ali (1951), the Privy Council held that a license commissioner was not acting quasi-judicially because the statute did not explicitly superadd a duty to act judicially.

• This created a major barrier to challenging arbitrary administrative decisions.

• The Ridge v. Baldwin Revolution: In the historic English House of Lords case of Ridge v. Baldwin (1964), this restrictive approach was discarded.

• Lord Reid analyzed classical authorities and concluded that the "duty to act judicially" is not something that needs to be superadded by a statute.

• Instead, the duty to act judicially is implied from the very nature of the power itself.

• If an administrative authority has the power to decide a matter that affects the rights, status, or livelihood of an individual, the duty to act judicially (and thus follow natural justice) is inherent in that function.

• This case broke down the rigid distinction between administrative and quasi-judicial acts, establishing that even purely administrative bodies must act fairly.

• Therefore, the test was finally settled in Ridge v. Baldwin, making Option (A) the correct choice.

Step 4: Final Answer:
The House of Lords settled the "duty to act judicially" test by implying it from the nature of the power in *Ridge v. Baldwin*, making Option (A) the correct answer.