Sampath Kumar vs. Union of India
(1987) 1 SCC 124
Case Summary
Administrative Tribunals
FACTS
The case of S.P. Sampath Kumar v. Union of India revolved around the constitutional validity of Section 28(1) of the Administrative Tribunals Act, 1985. The Act was established under Article 323-A of the Indian Constitution to provide an alternative mechanism for adjudicating disputes related to the recruitment and conditions of service of public officials. However, the Act effectively removed the jurisdiction of the High Courts under Articles 226 and 227, raising concerns about the violation of the basic structure of the Constitution, specifically the doctrine of judicial review. The petitioners challenged the exclusion of High Court jurisdiction and the composition of the Administrative Tribunals as being unconstitutional.
RELEVANT ARTICLES
Article 323-A - Provided for the establishment of administrative tribunals.
Article 226 & 227 - Granted High Courts the power of judicial review.
Article 32 - Ensured fundamental rights enforcement through the Supreme Court.
Article 136 - Allowed the Supreme Court to exercise appellate jurisdiction.
ISSUES
Whether Section 28 of the Administrative Tribunals Act, 1985, which excluded the jurisdiction of the High Courts in service matters and conferred exclusive jurisdiction on tribunals, was unconstitutional.
Whether the composition of the Administrative Tribunals, including the appointment of its Chairman, Vice-Chairman, and Members, violated constitutional provisions by affecting the independence of the judiciary.
JUDGMENT
The Supreme Court held that since administrative tribunals were replacing the High Courts in service matters, the qualifications for appointment to such tribunals should be equivalent to those of High Court judges. It struck down Clause (c) of Section 6(1) of the Act, which allowed non-judicial members (such as a Secretary to the Government of India) to be appointed as Chairman of a tribunal. The Court emphasized that judicial review is a fundamental aspect of the Constitution's basic structure and cannot be completely removed. While it upheld the validity of tribunals, it maintained that the exclusion of the High Court’s jurisdiction does not prevent judicial review entirely, as the Supreme Court still retained its appellate and original jurisdiction.
The Court relied on Minerva Mills Ltd. v. Union of India, where it was held that any constitutional amendment limiting the jurisdiction of the High Courts without providing an effective alternative remedy would be unconstitutional. The Court concluded that administrative tribunals must function in a manner that ensures legal expertise and safeguards judicial independence, thus upholding the integrity of the judiciary within the framework of the Constitution.
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