Background of the Case: L. Chandra Kumar v. Union of India is a landmark case that addressed the constitutional validity of the provisions of the Administrative Tribunals Act, 1985, which sought to transfer jurisdiction from High Courts to administrative tribunals for adjudication of disputes relating to service matters of public servants.
Key Issues Raised:
Whether the provisions of the Administrative Tribunals Act, 1985, which transferred jurisdiction from High Courts to administrative tribunals for adjudication of service matters, were violative of the basic structure doctrine and the principle of independence of the judiciary?
Whether the establishment of administrative tribunals and the transfer of jurisdiction from High Courts to these tribunals affected the independence and impartiality of the judiciary?
Whether the creation of administrative tribunals for adjudication of service matters was consistent with the separation of powers doctrine enshrined in the Indian Constitution?
Arguments from Both Sides:
L. Chandra Kumar (Petitioner): He argued that the transfer of jurisdiction from High Courts to administrative tribunals undermined the independence and impartiality of the judiciary, as administrative tribunals were not vested with the same level of autonomy and neutrality as the High Courts. He contended that the provisions of the Administrative Tribunals Act, 1985, violated the basic structure of the Constitution.
Union of India (Respondent): The government defended the constitutionality of the Administrative Tribunals Act, 1985, asserting that the establishment of administrative tribunals was aimed at expediting the resolution of service-related disputes and ensuring effective administration. It argued that administrative tribunals were specialized bodies equipped to deal with technical and specialized issues concerning public servants.
Judgement: In 1997, the Supreme Court of India delivered its judgement in L. Chandra Kumar v. Union of India, declaring certain provisions of the Administrative Tribunals Act, 1985, unconstitutional. The Court held that the provision which ousted the jurisdiction of the High Courts in service matters was violative of the basic structure doctrine and the principle of independence of the judiciary.
The Court ruled that while administrative tribunals could be created to deal with specialized issues, their jurisdiction could not oust the jurisdiction of the High Courts entirely. It held that the power of judicial review vested in the High Courts was an essential feature of the Constitution’s basic structure and could not be abrogated or diluted.
Significance: L. Chandra Kumar v. Union of India is a significant judgement that reaffirmed the importance of the independence of the judiciary and the jurisdiction of the High Courts in the Indian constitutional framework. The judgement clarified that while administrative tribunals could be established to deal with specialized matters, they could not entirely replace the jurisdiction of the High Courts. The case has had a lasting impact on the structure of administrative justice in India and the balance of powers between the judiciary and the executive.