"Reasons Are Heartbeat Of Every Conclusion": J&K High Court Quashes Order Lacking Reasons For Condonement Of Delay

A bench of Justice Javed Iqbal Wani emphasised that reasons are the heartbeat of every conclusion and struck down an order that failed to explain the rationale behind condoning a significant delay in an appeal.

The case involved a land dispute in Jammu. Balbir Singh, Pritam Singh, and Ravinder Singh (petitioners) challenged an order passed by the Commissioner Agrarian Reforms ( respondent) condoning a delay of 15 years in an appeal filed by the private respondents. The appeal contested a land mutation (transfer) in favour of the petitioners.

The petitioners argued that the respondent authority had not provided any justification for condoning such a lengthy delay, thereby violating their right to a fair hearing.

Reiterating the fundamental principle that "reasons are the heartbeat of every conclusion," Justice Wani emphasized that both administrative and judicial/quasi-judicial orders must be supported by reasons to ensure transparency and accountability in the justice delivery system.

“..Recording of reasons is the heartbeat of every conclusion as it introduces clarity in an order and without the same, the order becomes lifeless and the absence of reasons renders an order indefensible/unsustainable particularly when the order is subject to further challenge before a higher forum”, the bench remarked.

The Court referenced the landmark judgment of the Supreme Court in the case of "Union of India Vs Ibrahim Uddin and Anr." 2012, which emphasized the necessity of recording reasons in order to facilitate clarity and ensure the proper application of mind by the adjudicating authority.

Analyzing the impugned order, Justice Wani observed that the appellate authority had failed to provide any reasons for condoning the substantial delay and consequently held the order legally unsustainable.

Accordingly, the bench directed the matter to be reconsidered by the Commissioner Agrarian Reforms Rajouri, with a mandate to provide adequate reasons and afford an opportunity of hearing to all concerned parties.

Case Title: Balbir Singh Vs UT of J&K

Citation: 2024 LiveLaw (JKL) 76

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