NAWABKHAN ABBASKHAN versus THE STATE OF GUJARAT

NAWABKHAN ABBASKHAN versus THE STATE OF GUJARAT

An order made in violation of the audi alteram partem rule and which infringes a constitutionally guaranteed right is void ab initio and confers no legal obligation on the citizen. Hence, violation of such an order cannot constitute an offence, and acquittal must follow.

Parties
Appellant: Nawabkhan Abbaskhan; Respondent: State of Gujarat
Jurisdiction
India
Judgment Date
19 February 1974
Procedural Posture
Criminal Appeal / Appeal Against Conviction by High Court
Outcome
Appeal allowed; acquittal ordered
Legal Topics
Natural Justice, Void and Voidable Orders, Externment, Article 19 – Fundamental Rights, Audi Alteram Partem

Case Brief

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Parties

Nawabkhan Abbaskhan

Appellant

State of Gujarat

Respondent

Procedural Posture

Criminal Appeal / Appeal Against Conviction by High Court

  1. 1 Whether the externment order, having been quashed by the High Court during the pendency of the criminal trial, was void ab initio and therefore no offence was committed by the appellant for its contravention
  2. 2 Effect of violation of natural justice (audi alteram partem) on statutory orders restraining fundamental rights

Ratio Decidendi

An order made in violation of the audi alteram partem rule and which infringes a constitutionally guaranteed right is void ab initio and confers no legal obligation on the citizen. Hence, violation of such an order cannot constitute an offence, and acquittal must follow.

Court Disposition

Appeal allowed; acquittal ordered

Orders

  • Appellant acquitted of the charge under Section 142 of the Bombay Police Act, 1951.