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The leading case on personal bias under Indian administrative law is *Mineral Development Ltd. v. State of Bihar, AIR 1960 SC 468*. What was the holding?
Answer & Solution
Correct answer: C.
1. **Mineral Development Ltd. v. State of Bihar, AIR 1960 SC 468** is the leading authority on **personal bias**.
2. The Minister of Revenue had cancelled the petitioner company's mica licence. The owner had **opposed the Minister in the 1952 general election** and the Minister had earlier filed a criminal case under Section 500 IPC against the owner.
3. The act of cancellation by the Minister was held to be a **quasi-judicial act**. Since the personal rivalry between the owner and the Minister was established, the cancellation order was **vitiated in law** on the ground of personal bias.
4. The companion case *Manek Lal v. Prem Chand, AIR 1957 SC 425* held that even where the inquiry tribunal Chairman had no direct contact with the client, he was disqualified — 'justice must not only be done but must appear to be done'.
_Source: ICSI CS Executive — Lesson 5, 'Personal bias', p. 125._
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