AN INSIGHT INTO EXECUTIVE DISCRETION

By
FAKHAR MAHMOOD MAKHDOOM*

PREFIXTURE

            The grant of wide discretionary powers, which was once believed to be incompatible with the concept of rule of law has now became a necessary by product of the modern welfare state.[1] The rapid and phenomenal growth in functions of state during the present century has necessitated the grant of wide discretionary powers to a variety of public bodies and officials. Since these powers and discretion of executive bodies are linked with the valuable rights of the citizens therefore, its exercise must be regulated so as to protect the common man from despotism. The legal concept of discretion implies power to make a choice between alternative courses of action. If only one course can lawfully be adopted, the decision taken is not the exercise of a discretion but the performance of a duty.[2] It is generally accepted notion that the exercise of any public power is subject to express and implied limitations imposed by law.[3]

The scope of judicial review of such discretion will often be determined mainly by the wording of a power and the context in which it is exercised.[4] Thus the legislature while granting discretionary powers imposes some conditions e.g. to record reasons of decision, to consult the interested person, to hold a public inquiry before taking any action under the statute.

In Britain, the principle of judicial review was stated by Lord Atkin as follows:[5]

“In accordance with British Jurisprudence no member of the executive can interfere with the liberty or property of a British Subject except on the condition that he can support the legality of his action before a court of justice”.

The courts insist that the grant of discretion in always accompanied by certain implied conditions which guard against the irresponsible exercise of powers. The control of discretionary powers
is perhaps the most critical problem of the modern Administrative
Law.[6]

An administrative body is under a duty to act justly, fairly and reasonably,[7] and where it acts unreasonably, capriciously, or arbitrarily, the court will interfere with its judgment.[8] Long ago chief justice Coke laid down the rule in Rookes case (1598) that discretion is “a science or understanding to discern between falsity and truth, between right and wrong, between shadow and substance, between equity and colourable glosses and pretences and not to do according to wills and affections.”[9] Normally courts do not enter into the complexities of modern administered process and they are usually concerned only with the control of illegal exercise of discretion.

English Common Law has developed certain general rules regarding exercise of discretion. In Robert vs Hopwood[10] a borough council empowered under the Act to pay such wages to their employees as it “may think fit”, paid over generous wages and the district auditor disallowed the payments. On challenge the decision of auditor was ultimately upheld by the House of Lords. Lord Wren bury held that a discretion does not empower a man to do what he likes merely because he is minded to do so…he must, by the use of his reason, ascertain and follow the course which reason directs. He must act reasonably. 

In wednesbury case[11] Lord Greene MR observed, “It is true that discretion must be exercised reasonably. A person entrusted with discretion must direct himself properly in law. He must call his own attention to the matters which he is bound to consider. He must exclude from his consideration matters which are irrelevant to what he has to consider. If he does not obey these rules, he may truly be said to be acting unreasonably.

In padfield vs Minister of Agriculture, Fisheries & Food[12] the action of the minister refusing to forward the complaint to the investigation committee on irrelevant ground was held to be abuse of discretion similarly in Breen vs Amalgamated Engineering Union[13] Lord Denning MR relying on Padfield case observed that, “discretion of a statutory body is never unfettered, it is to be exercised and guided by relevant and plausible considerations”.

Again it has been held in a number of celebrated cases in England that exercise of discretion should not be fettered by over rigid policies so hat in the exercise of discretionary powers every case must be decided on its own merits and the compulsion of the public interests.[14]

In Pakistan courts have also developed similar principles of law to control the exercise of administrative discretion. Thus the Constitution of Pakistan and India require that the authority putting a person to Preventive Detention must communicate to such person, as soon as may be, the grounds of detention so as to enable him to make  representation.[15]

In Agha Muhammad Khan vs District Board Lahore[16] justice B.Z. Kaikaus observed,

“Any exercise of power which is arbitrary, oppressive and wanton is an abuse and is not an exercise of power within the meaning of the statute at all, all abuse in excess”

In Montgomery flour & general Mills Ltd. Vs Director Food Purchase[17] justice Kaikaus again observed that discretion of executive authority is always circumscribed by the scope and object of the law that creates it and has at the same time to be exercised justly, fairly and reasonably.

In Federation of Pakistan vs Muhammad Aslam[18] the Supreme Court has reitrated the rules to control and review the executive discretion. Justice Shafi-ur-Rehman observed,

“The limit now well recognized is that all executive power has to be exercised fairly and justly, for advancing the objects of legislation. In other words every such exercise of power has to satisfy the test of reason and relevance.”

1.         ABUSE / EXCESS OF DISCRETION

i)          Malafides

Malfides or bad faith means dishonest intention or corrupt motive. The Supreme Court of India has observed,

malafide exercise of power does not necessarily imply any moral turpitude as a matter of Law. It only means that the statutory power is exercised for purposes foreign to those for which it is in law intended”.[19]

In this sense, malafides is equated with any ultra vires exercise of administrative power. However the term malafides is not being used in the broad sense, but in the narrow sense of exercise of power out of dishonest intent or corrupt motive. Malafides in this narrow sense would include those act where the motive behind an administrative action is personal animosity, spite, vengeance, personal benefit to the authority itself or to its relatives or friends, or which is designed to favour[20] or harm someone[21].

Malafides is a question of fact which must be established by evidence[22] however High Court can enquire into malafides if the disputed question of fact can be ascertained from the documents on record.[23] Where government took a disciplinary action to ensure probity and purity in the public service and not to wreak personal vengeance, it was declared not to be malafides or ultra vires but at the some time it is clear that malafides is a distinct ground for quashing administrative action apart from ultra  vires.[24]

Furthermore, it has been ruled in number of case that the plea of malafides is not available against the Legislative Action[25] and somewhat surprisingly it has been so ruled even in a case of a law made by an individual for example a Martial Law Administrator.

ii)         Unreasonable and Arbitrary Action 

            The Superior courts in Pakistan have quite often ruled that the public powers must not be exercised arbitrarily. The court has held invalid the exercise of discretionary powers when the action is not based on any relevant material.[26] An action meets the some fate if it is based on unfounded grounds[27]  or on such grounds on which reasonable person would consider valid.[28] The courts demand that the repository of public power must apply his mind to all the relevant aspects of the matter before taking an action. Thus an order of Deputy Commissioner to take over a cinema as enemy property under Defence of Pakistan Rules (1965) made without application of mind and without giving any reason has been held invalid.[29]

Similarly the action was held invalid when an election tribunal based its findings on the solitary evidence of the election officials[30] or a criminal court gave temporary possession of the crime property to a  person not at all entitled to it.[31] Where malice was imputed for procuring order which from circumstances seemed to be possible, the supreme court of Pakistan held that unless the same was explained by the concerned administrative authority, it would be difficult to justify it.[32]

The authority while passing orders in administrative matters must follow rules and principles of justice and equity so that even when such order has been passed should not stamp such order as malafides and result of bias or malice[33]. It is not necessary for the individual to prove what particular official of the government acted malafides. There is no such burden on the individual as facts lie within the knowledge of the government.[34]

iii)        Improper Purpose

            If a statute confers powers for one purpose, its use for a difficult purpose would not be regarded as valid exercise of power and the same could be quashed. for instance the government my be empowered to acquire property if its is “satisfied” to the existence of  public purpose, its order would be legal, provided of course that the circumstances which it has found to exist do in Law constitute  public purpose.[35]

            In the area of preventive detention, it has been held in a few cases that the power of preventive detention cannot be used as a convenient substitute for persecuting a person in a criminal court. It was held that the power of detention could not be used on “simple solitary incident” of theft of railway property, and the proper course to persecute the person was in criminal court. In some of the cases the court has used the phrase “colourable exercise of power”[36] which term does not differ substantially from improper purpose. It has however been ruled in some cases that a prior  court case, or lack of it would not make the detention order invalid.[37]

iv)        Irrelevant considerations

            A power conferred by a statute must be exercised on the consideration mentioned in the statute or relevant to the purpose for which it is conferred whenever administrative authority is given power to pass some order, it should exercise its authority independently by taking into consideration all relevant circumstances where such an authority had made decision and issued order there under, under extraneous influence such order should be quashed as invalid.[38] Thus public functionary vested with power in respect of determination of rights of a citizen qua the state resources is required to exercise the same fairly and properly on sound judicial principles and keeping in view relevant considerations having logical nexus with the object of law and not arbitrarily and whimsically.[39]

2.         FAILURE TO EXERCISE DISCRETION

            A statutory functionary who is given discretionary powers under the statute is required to exercise these powers by applying his independent mind and without being influenced by others. Where a scheme was published by the manager without the corporation applying its mind to the case before it and the scheme was approved by the governor, the court held it invalid because the corporation had not applied its mind.[40] In the Province of East Pakistan vs Jogesh Chandra Lodh.[41] Chief Justice Munir observed,

“It is perfectly clear from this proceeding that the additional district magistrate who made the order under section 3 merely acted as a tool to the land acquisition department of the government and did not at all apply his mind to the question whether it was necessary or expedient to requisition the property for a public purpose on this ground alone, therefore the order must be held to be invalid”.

In another celebrated case[42] justice Hamood-ur-Rehman ruled, “we are of the opinion that it behaved the chief settlement commissioner to apply his own independent mind to the questions raised before him and to deal with the three revision petitions put up before him according to law. By merely countersigning the note of settlement commissioner we are clearly of the view that he had not exercised the jurisdiction vested in him in accordance with law”. The Lahore High Court quashed n administrative decision when it was found to be taken on dictation of another which was required to be taken on dictation of anther which was required to be taken by the authorized administrative authority on his independent judgment.[43]

In Sher Mohammed vs Abdur Rasheed,[44] Supreme Court has termed such as action as “abdication of jurisdiction, surrender of discretion and refusal to exercise jurisdiction.

3.         THE SUBJECTIVE FORMULATION OF POWER AND JUDICIAL REVIEW

            “Reasonableness” provides quite a flexible basis for the court to interfere and in other factual situations requiring reasonable administrative action, the scope of judicial review may be much wider. In such situation the scope of judicial review is determined by practical realities and it would be absorbed to suppose that the attitude of the courts towards such words as “reasonable grounds” in one legislative context must be reproduced in every other.[45] This may be elaborated with reference to two classical English cases.

In Liversidge vs Anderson[46] being a war time case, involved a regulation of the defense, involving implication of the use of the term “reasonable” in a statute, which ran as follows:

“If the secretary of state has reasonable cause to believe any person to be of hostile origin and that by reason thereof it is necessary to exercise control over him he may take an order against that person directing that he be detained”.

The House of Lords was faced with the question whether the words “reasonable cause to believe” should be given on objective or subjective meanings. The House of Lords interpreted the words subjectively and held that parliament had conferred an absolute discretion on executive who is not bound to satisfy any body else. This ruling was criticized as it disclosed a definite bias in the courts towards subjective interpretation. In Nakkuda Ali vs Jayaratne[47] The privy council stated that it would be very unfortunate if the decision in the Liversidge case came to be regarded as laying down any general rule as to the construction of such phrase the court further held that when the legislature used the word “reasonable” it must have been intended to serve in some sense as a condition limiting the exercise of an otherwise arbitrary power.

But f the question whether the condition has been satisfied, is to be conclusively decide by the man who wields the power, the value of the intended restraint would in effect be nothing the courts have on the whole, been extremely reluctant to impart the requirements of reasonableness (at least in the broad sense of going into the merits) into a statute by implication. While quashing own executive action under the Companies Act. 1956 the Supreme Court of India stated in Rohtas industries vs S.D. Agarwal.[48]

“We do not think that any reasonable person much less any expert body like the government on the material before it, could have jumped to the conclusion that there was any fraud involved in the sale of the shares in question”.

            It is an overriding principle of the French Administrative Law that an administrative act is proper and therefore lawful only if it is reasonable, the opposite of capricious, or arbitrary, and further the administrator must produce the reason before the tribunal (counsel d` Etat) whenever it thinks that there is sufficient ground for producing the reason.[49]

            In Mardana Mosque Trustees vs Mahmud[50] the Privy Council interpreted the orders “where the minister is satisfied” and held that there must be some grounds n which the minister could be satisfied. The judicial trend was finally approved by the House of Lords in Tameside case[51] However the English courts were no more sympathetic towards Liversidge rule being war time case yet it took them about forty years to complete its burial. The Rule of Liversidge was also applied in India by Privy Council[52] But after independence our courts quietly started ignoring the Liversidge Rule[53].

Similarly the Lahore High Court held[54] that the satisfaction of executive must be based on some tangible material. The Supreme Court Pakistan has vividly interpreted[55] the word “satisfaction” of detaining authority must be state of mind which has been induced by the existence of reasonable grounds for such satisfaction.

In summary, the courts are not willing to concept that their jurisdiction, particularly the constitutional jurisdiction can be ousted by the use of subjective language. This is quite justified for the reason that otherwise the executive will be armed with arbitrary power which will seriously hamper the Rule of Law, cause of justice and fair play.

EPILOGUE

            From the foregoing elaboration, it has been established that grant of discretionary power is never unlimited and that the judiciary has placed some restrictions on exercise of such powers to ensure that the same is being used in a responsible and sensible manner. The counseil d’Etat in France has gone for in the direction of requiring executive decisions t contain reasons.

In Britain the Tribunals and Inquiries Act 1958 imposes a statutory duty to give reasons in administrative adjudication. In Pakistan in 1997, through on Amendment in General Clauses Act 1897 by inserting there section 24A, which requires that the authority, officer or person making an order or issuing any direction under the power conferred by or under any enactment should, as far as necessary or appropriate, give reasons for making the order or issuing the direction. This mechanism has helped all those aggrieved persons who want to challenge administration adjudication in judicial review in superior courts, which are not willing to surrender their jurisdiction to intervene even when the legislature formulates the grant of discretion in subjective expressions. The recent judicial activism will go a long way to safeguard the interests of common man of Pakistan being subject of acute despotism t the hands of executives, since ages.



*  Assistant Professor of Law, International Islamic University Islamabad, Pakistan.

[1] A.V Dicey, “Law of the Constitution”. Ch. 4. (10th ed) 202

[2] S.A., de Smith, “Judicial Review of Administrative Action”. 4th ed. 1980. Pg. 278

[3] H.W.R. Wade, “Administrative Law”. 6th ed. (1994) Pg. 348

[4] Secretary of state for education & science vs Tameside M.B.C. (1977) A,C,. 1047 per Lord Wilberforce. (“But there is no universal rule as to the principles on which the exercise of  discretion may be reviewed, each statute or type of statute must be individually looked at”)

[5] Eshugbayi vs Government of Nigeria (1931) L.R. 670 (C.A)

[6] See Final Report of the Bland Committee on Administrative Discretion (1973)

[7] Hadi Ali vs Govt. of West Pakistan PLD 1956 Lah. 824

[8] Abdul Majid vs Province of West Pakistan PLD 1956 Lah. 615; R Vs Bishop of London (1889)   

   24QBD213; Robert vs Hopwood (1925) A.,C. 578

[9] [1598] 5 Co. Rep. 996

[10] [1925] A.C. 578

[11] Associated Provincial Pictures House Ltd. Vs Waynesburg corporation [1948] 1-kB 223

[12] [1968] A.C 997

[13] [1971] 2 QB175 at Page 190

[14] R VS Hillingdon B.C. ex. P. Islam [1983] AC 688, R Vs London C.C. [1918] 1 KB 68

[15] Article 10 of Pakistan Constitution 1973, article 22 (5) of Indian constitution.

[16] PLD 1957 Lahore 780 at P. 783

[17] PLD 1957 Lah. 914

[18] 1986 CMR 916 at pp. 928-929 see also PLD 1989 SC 162

[19] Jaichand vs West Bengal AIR 1967 SC 483-at P. 485

[20] Ahbab Corporative Housing Society vs Commissioner Lahore Division PLD 1978 Lah 273

[21] Province of Punjab vs Zahoor Elahi PLD 1981 Lah. 696 upheld in 1982 SCMR 172

[22] Masood Ahmad vs State PLD 1962 Lah 878, PLD 1974 Karachi 375

[23] Akhtar Hussain vs Ahangoo Khan 1981 CLC 1971

[24] S.A de Smith, “Judicial Review of Administrative Action”. (1973) edn. P. 282 at p. 293

[25] Fouji Foundation vs Shamim ur Rehman PLD 1983 SC 457

[26] Charsadda Sugar Mills vs Govt. of Pakistan. PLD 1971 Pesh. 210, PLD 1981 Lah. 368 1982 CLC 2101

[27] Muhammad Aboo Abdullah vs Province of East Pakistan. PLD 1959 Daca 361

[28] Muhammad Ali vs Election controlling authority PLD 1963 Lah. 346

[29] Malina Rani Sons vs province of East Pakistan PLD 968 Dcca 177

[30] Shafiqur Rehman VS M.S. Mian PLD 1968 Dacca 332

[31] Abdur Rashid vs Sessions Judge PLD 197 Lah. 613

[32] University of the Punjab vs Ruhi Farzan 1996 SCMR 263

[33] Ibid

[34] State of Punjab vs Ramjilal AIR 1971SC 1228

[35] Muhammad Jamil Asghar vs the improvement Trust. PLD 1965 SC 698

[36] ZafarulAhsan vs The Republic of Pakistan. PLD 1960 SC 113

[37] Samir Chatterjee vs state of west Bengal. AIR 1975 SC 1165

[38] Jawed Hotel vs CDA, PLD 1994 Lah. 315, Arif Builders vs Govt. of Pakistan PLD 1994 Kar 627

[39] Muhammad Zahoor ul Ha vs Quarter Master General 1994 CC 2449

[40] Manikehchandra vs state AIR 1973 Gau. 1

[41] 11 DLR (Sc) 411

[42] Ghulm Mohi-ud-Din vs Chief Settlemnt Commisoner PLD 1964 SC 829

[43] Ahmad Zaman Khan vs Governmnet of Pakistn. PLD 1977 Lah. 735

[44] 1980 SCMR 928

[45] S. de Smith, “Judicial Review of Administrative Action”. 1973 ed. Pg. 306 46. (1942) A.C. 206

[46] (1942) A.C. 206

[47] (1951) A.C. 66

[48] AIR 1969 S.C. 707

[49] Hamson. “Executive Discretion & Judicial Review” (1954) 495.

[50] (1967) AC 13

[51] (1977) AC 1014

[52] Sibnath Banerj is case. LR 72, 1A 241 & Vimlabai Dispande’s case LR 71 1A, 114

[53] Ghulam Mohammad Khn vs Crown. PLD 1949 Sind 12

[54] Sakhi Daler Khan’s case PLD 1957 Lah. 8B

[55] Ghulam Gilani vs Govt. of West Pakistan. PLD 1968 SC 373