A.K. Kraipak v Union of India (1969)

Administrative Law · Classification of Administrative Functions

Facts.

A selection board chose officers for the Indian Forest Service. One of the members of the board was himself a candidate for selection and took part while his own name was considered.

Issue.

Did natural justice apply to what was arguably a purely administrative selection, and was the selection vitiated by the member’s participation?

Held.

The Supreme Court held the selection bad. The dividing line between administrative and quasi-judicial functions is thin and fading; the rules of natural justice apply to administrative action too, and no one can be a judge in his own cause.

Why it matters.

It fused the two categories for the purpose of fairness — after Kraipak, the administration must act fairly whether its act is labelled administrative or quasi-judicial. It is the pivot between Unit 1 (classification) and Unit 3 (natural justice).

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