A.P. State Road Transport Corpn. and Anr vs Sri Satyanarayana Transports Pvt. Ltd.

Rewritten Version Notice: This is a rewritten version of the original judgment.

Court: Supreme Court of India

Case Number: Appeal (civil) 382-386 of 1962

Decision Date: 05/10/1964

Coram: P.B. Gajendragadkar (CJ), K.N. Wanchoo, M. Hidayatullah, R. Dayal, J.R. Mudholkar

A.P. State Road Transport Corpn. & Anr versus Sri Satyanarayana Transports Pvt. Ltd. was decided by the Supreme Court of India on 5 October 1964. The bench that heard the matter consisted of Chief Justice P.B. Gajendragadkar together with Justices K.N. Wanchoo, M. Hidayatullah, R. Dayal and J.R. Mudholkar. The appeal, numbered 382‑386 of 1962, was filed by the Andhra Pradesh State Road Transport Corporation and the State of Andhra Pradesh against five writ petitions that had been presented in the Andhra Pradesh High Court by the respondents, including Sri Satyanarayana Transports Pvt. Ltd., Guntur and others. The writ petitions challenged the legality of orders issued by the State of Andhra Pradesh under section 68D(2) of the Motor Vehicles Act (No. 1 of 1939) on 18 October 1960, orders that approved schemes for the nationalisation of bus transport in the Guntur area. Prior to that, on 26 May 1960, the State of Andhra Pradesh had published ten schemes in the Andhra Pradesh Gazette for taking over the road‑transport services of private operators in Guntur under Chapter IVA of the Act. The Gazette called for objections from those affected by the schemes. The Minister of Transport, Mr S. P. B. Pattalhi Rama Rao, heard the objections and, after making minor modifications, gave his approval on 18 October 1960. He directed that the schemes should become effective on the dates specified in the Government Orders, and these schemes were formally notified by Government Order numbers 2230 to 2239 in the Extraordinary Gazette dated 27 October 1960. The five writ petitions were specifically directed against the ministerial order of 18 October 1960.

In the writ petitions, the respondents contested the validity of the impugned order on several grounds. They argued that the initial publication of the proposed schemes under section 68C was defective because it did not state the dates on which each scheme would take effect, thereby depriving them of a reasonable opportunity to lodge objections. They further maintained that the order gave the Chief Executive Officer the power to implement the schemes in a piecemeal manner, which they claimed rendered the order invalid. Additional arguments were also raised, but the High Court rejected all of them and, had it not been for a further allegation in writ petition No. 868 of 1960, would have dismissed the petitions outright. In that particular petition, an extra contention was advanced challenging the validity of the order, setting the stage for the present appeal.

The petition argued that the State Government’s approval of the schemes represented a colourable use of its authority under the Act because the Minister responsible for Transport was alleged to have held a personal bias against Mr. Thummala Ramakotaiah, who was one of the petitioners. In support of this claim, affidavits were submitted by the petitioners, while the Minister filed counter‑affidavits denying the allegation of bias. The High Court examined the evidence and concluded that the affidavits sufficiently demonstrated that, at the time the Minister considered the objections raised by the respondents to the notified schemes, his decision was influenced by bias. Accordingly, the High Court set aside the impugned order. The Court also observed that Ramakotaiah, a petitioner in W. P. No. 868/1960, had not raised his objection before the Minister when the Minister dealt with the relevant schemes under Section 68D(2). In the High Court’s view, this omission barred the petitioners from relying on the bias argument within their writ petition. Nevertheless, once the bias was established, the Court held that the Minister’s order was legally infirm because the existence of bias disqualified him from hearing the objections to the notified schemes. For this reason, the entire impugned order was struck down, a result that, in the Court’s opinion, made no practical difference to the petitioners in W. P. No. 868/1960 since the order was wholly set aside. The appellants now approach this Court, seeking relief against the High Court’s orders in the five writ petitions, and the precise issue for determination is whether the High Court was correct in concluding that the Minister who dealt with the ten schemes under Section 68D(2) of the Act was incompetent to act because of his personal bias.

Before addressing that issue, the Court finds it necessary to outline the factual basis of the bias allegation. The allegation centers on an attempt by the Minister to enlist the assistance of Mr. Ramakotaiah in influencing the election of the Election Committee of the Andhra Pradesh Congress Committee, an election scheduled for 28 August 1960. At the relevant time, the Council of Ministers in the State of Andhra Pradesh was split into two antagonistic factions. One faction, referred to as the “power group” or “Ministerial group,” comprised ministers aligned with the governing side, while the opposing faction was known as the “United Front group.” The Minister in charge of Transport, hereafter referred to as the Minister, was identified as a leading member of the power group and was himself a candidate for a seat on the Election Committee. The rivalry between the two groups had led both sides to engage in extensive canvassing activities prior to the election date, creating a context in which the alleged request for Ramakotaiah’s assistance was made.

The Court noted that the Minister was among the leading members of the power group and that he himself had contested a seat on the Election Committee. Because of the intense rivalry between the power group and the United Front group, both sides engaged in vigorous canvassing before the election date arrived. The petitioner in W. P. No. 868 of 1960 was Sri Satyanarayana Transport (Private) Ltd., a company based in Guntur, and its managing director was Ramakotaiah. The company claimed that its shareholders were persons of influence. Ramakotaiah, in particular, held the positions of Vice‑Chairman of Narasaraopet Municipality and member of the Senate of Sri Venkateswara University at Tirupathi. He was personally acquainted with five members of the Andhra Pradesh Congress Committee, namely Ravipati Anjaneyulu, Nooti Venkateswarulu, Kapalavayi Kasi Rama Rao, Basivi Reddi and Bhuvanam Koti Reddi. The essential allegation against the Minister was that he sought Ramakotaiah’s assistance in persuading these five friends to vote for the Minister and the Minister’s group in the upcoming election. Ramakotaiah made an effort to comply with the Minister’s request, but he was unable to secure the desired votes. The Minister became very angry when Ramakotaiah informed him of this failure, and, according to Ramakotaiah, the Minister warned him that the consequences of his failure would be unbearable. In this state of anger, the Minister considered the objections raised by various transport operators and decided against Ramakotaiah’s company. Ramakotaiah presented this narrative as the basis of his claim that the Minister was biased against him, rendering the Minister unfit to handle the ten schemes covered by Section 68D(2) of the Act. The Court then turned to the factual chronology supplied by Ramakotaiah. The schemes of nationalisation were published on 26 May 1960, and notices pursuant to those schemes were issued a few days before the election of the Election Committee. The hearing of objections was scheduled for 3 September 1960, and Ramakotaiah received notice of that hearing date on 15 August 1960. On 16 August, a person named Sakamari Bhujaiah, who was a distant relative of the Minister, met the Minister, who instructed Bhujaiah to ask Ramakotaiah to meet him. Bhujaiah conveyed this message to Ramakotaiah on 18 August. The following day, 19 August, Ramakotaiah placed a trunk call to the Minister’s office in Hyderabad, and during the telephone conversation the Minister invited Ramakotaiah to meet him in Hyderabad. Accordingly, Ramakotaiah met the Minister on 26 August, at which time the Minister urged him to persuade his five acquaintances to vote for the Minister’s party. Ramakotaiah subsequently approached those five friends on 26 and 27 August, but he was unable to obtain their agreement, as they had already committed themselves to the United Front.

In this case, the Court recorded that after Ramakotaiah told the Minister he could not persuade his friends, the election was held on 28 August and the Minister lost. The Minister then heard the objections on 3 September and issued the contested order on 18 October 1960. The Court then explained the effect of the modifications made by the Minister in the ten schemes that had previously been printed as proposed schemes in the Gazette. According to the Court, the original numbering was altered so that scheme number one became number seven, number two became number eight, and number three became number nine. The alteration also changed number four to number one and number five to number two, while leaving number six unchanged. It further changed number seven to number four, number eight to number three, and number nine to number five, and it kept number ten in its original position. The Court noted that the three schemes involving Ramakotaiah’s company were originally numbered four, seven and nine, and that all of these had been moved to earlier positions in the revised order. Ramakotaiah claimed that this rearrangement had been done deliberately to cause serious financial loss to his company as a result. The Court further recounted an argument advanced on behalf of Ramakotaiah’s company, which asserted that the serial order in which the ten schemes were originally published in the Government Gazette under section 68C indicated that the schemes would be implemented in that same sequence. It was contended that the departure from that sequence and the substantial shifting of the positions of the schemes affecting Ramakotaiah’s company were malicious and intended to damage the company’s financial interests. The Court observed that the change in the order of the schemes had also been challenged on the ground that it violated article 14 of the Constitution. The High Court had rejected that plea, holding that the provisions of the Act ranging from section 68C through section 68F did not demonstrate that the serial numbers assigned in the proposed schemes published under section 68C were required to be adopted unchanged. The Court explained that the numbers assigned to the schemes served only as a convenient reference and indicated that the overall nationalisation scheme would be brought into force in stages, and nothing more. Consequently, the grievance that the alteration of the numbers amounted to discrimination under article 14 was dismissed by the Court.

Accordingly, the Court stated that it must proceed to consider the present appeals on the basis that the Minister was authorized to alter the numbers of the schemes. It also held that the Minister could decide the sequence in which the schemes would be implemented for the nationalisation process. Finally, the Court addressed the legal position concerning the allegation of bias against the Minister in this matter. The Court affirmed that the law on the issue of bias was settled and well established through numerous decisions. It reiterated that when the Minister heard the objections to the proposed schemes under section 68D (2), he was acting in a quasi‑judicial capacity. The Court further observed that his inquiry was required to conform to the principles of natural justice as dictated by established legal standards. The principles of natural justice required the decision‑maker to approach the matter without pre‑conceived notions and to give each party a fair opportunity to be heard. The Court observed that any indication of a personal financial interest or hostility toward a party could disqualify the Minister from performing the quasi‑judicial function. Having examined the material, the Court found no evidence of personal interest or hostility that would render the Minister biased.

The Court noted that when the Minister examined objections to the proposed schemes he performed a function that was quasi‑judicial, and therefore his inquiry was required to obey the principles of natural justice. An elementary rule of natural justice, the Court explained, mandates that any person who determines a case must approach the matter objectively, fairly and without prejudice. The Court cited Jewitt’s Dictionary of English Law, which states that “anything which tends or may be regarded as tending to cause such a person to decide a case otherwise than on evidence must be held to be biased.” Accordingly, a direct pecuniary interest in the subject matter constitutes a clear case of bias that disqualifies a decision‑maker from trying the cause. Likewise, hostility toward a party whose case is to be heard also creates the infirmity of bias and can disqualify the adjudicator. In discussing bias, the Court reminded that “no one can act in a judicial capacity if his previous conduct gives round for believing that he cannot act with an open mind.” The universally accepted broad principle, the Court affirmed, is that even in quasi‑judicial proceedings a decision‑maker must not only act fairly but must also be free from any suspicion of unfairness. The Court then referred to the decision in Franklin v. Minister of Town and Country Planning, [1947] K.B. 702, observing that the term ‘bias’ should be confined to its proper sphere and signifies a departure from the standard of even‑handed justice required of those occupying judicial or quasi‑judicial offices, such as arbitrators, because they must decide between parties without favouring one side. Applying this legal position on personal bias, the Court held that there would be no difficulty in concluding that the Minister should be disqualified from hearing the objections raised by the various bus operators to the ten schemes if the material facts alleged by Ramakotaiah are proven. The Court could not dispute that the Minister had asked Ramakotaiah to assist him in securing election to the Election Committee of the Andhra Pradesh Congress Committee, and when Ramakotaiah stated that he was unable to help, the Minister threatened him with serious consequences. Such a threat, the Court said, would create a serious infirmity in the order passed by the Minister under section 68D(2). The Court further observed that Ramakotaiah did not raise this objection at the time the Minister initiated the proceedings under section 68D(2). Ramakotaiah later attempted to justify his conduct by claiming that he did not believe the Minister would actually carry out the threat, and therefore he hoped no injustice would occur to him. He also alleged that he considered it unwise to raise the objection because he feared the objection would be over‑ruled and that the Minister would inevitably decide against him.

In this case the Court found that the explanation offered by Ramakotaiah – that he refrained from raising his objection at the earlier stage because he feared the objection would be dismissed and that the Minister would inevitably rule against him – was not satisfactory. Accordingly, the Court held that while dealing with the present appeal it must keep in mind the original weakness in Ramakotaiah’s position, namely his failure to present the objection at the proper procedural stage. The Court observed that the High Court had correctly held, and that the Court agreed with, that if the controversy were confined solely to the matter raised by Ramakotaiah, he would have been precluded from raising that contention in the writ proceedings. Nevertheless, the Court said it could not ignore the implication that, should Ramakotaiah’s allegations of bias be proved, the order under challenge would become invalid because it would have been issued by a person disqualified by personal bias. The Court emphasized that the basic rule of natural justice requires that any person who adjudicates, even in a quasi‑judicial proceeding, must not be affected by personal bias. This rule, the Court noted, cannot be confined to considerations that relate only to Ramakotaiah and that would have no relevance to the respondents’ complaints regarding the validity of the impugned order. For that reason the Court deemed it necessary to examine whether Ramakotaiah had succeeded in proving his case of bias against the Minister.

The specific issue placed before the Court was limited in scope. Both parties had filed affidavits in support of their respective contentions, and the final decision would necessarily depend on which set of affidavits the Court found credible. The High Court had concluded that the affidavits submitted on behalf of Ramakotaiah were satisfactory, whereas the Minister’s responses to the material points of dispute were evasive and unsatisfactory. Consequently, the matter turned on the appraisal of affidavit evidence. Ordinarily, the Court expressed a reluctance to disturb the factual findings of the High Court on such evidence. However, the High Court had issued a certificate to the appellants, indicating that it considered it necessary, in the interests of justice, to give the appellants an opportunity to present their position before this Court. The Court observed that where the finding of bias concerns a high public officer performing quasi‑judicial functions, the allegation of bias must be examined carefully before any adverse verdict is issued. The Court inferred that the High Court must have believed that, in the interest of fairness, the Minister should be allowed to challenge the High Court’s conclusion. That, the Court suggested, was the reason the High Court granted a certificate permitting the appeals to be brought before this Court.

In considering the matter, the Court kept in mind that a party who loses before a quasi‑judicial tribunal may become frustrated and angry, and may consequently make accusations of bias in a casual or irresponsible manner. It is not uncommon for litigants who are unsuccessful, whether in ordinary courts or before quasi‑judicial bodies, to be unwilling or unable to accept the correctness of the decision and to attribute that decision to a personal bias on the part of the judge or the tribunal. The transport sector, in particular, involves large financial stakes, and an operator who perceives that the implementation of a nationalisation scheme severely damages his business may, in his frustration, resort to a desperate strategy of alleging serious bias against the Minister who authorised the scheme. The Court recognised that this possibility could not be ignored when evaluating allegations of bias in cases of this nature.

The Court also noted that, on the balance of probabilities, a person occupying the high office of a State Minister would not ordinarily behave in the way alleged against the Minister in the present case. The learned Solicitor‑General contended that the accusations advanced by Ramakotaiah were overly crude to be credible, questioning why the Minister would approach Ramakotaiah for assistance and, if that assistance proved unavailable, why the Minister would threaten him. This line of argument appeared to have some initial plausibility. Nevertheless, the Court observed that when a Minister is vested with extensive discretionary powers to implement a nationalisation programme, it is not impossible for him to be subconsciously influenced by bias if such bias were proven. At the relevant time, a fierce struggle for political power existed between two factions within the Andhra Pradesh Council of Ministers, and each important member of the rival groups would likely strive to gather as much support as possible for his side. In political contests, a candidate cannot rely solely on personal dignity or status; he must be willing to employ aggressive tactics to secure votes, and anyone capable of delivering votes assumes significant importance. The record demonstrated that the rivalry had escalated to a point where large‑scale vote‑canvassing was in full swing, making it reasonable to assume that such political maneuvering was occurring. This backdrop formed the context within which the Court had to assess the allegations put forward by the parties.

In considering the general matters previously outlined, the Court emphasized that when evaluating evidence it must proceed with extreme caution, circumspection, and care. If the material presented by the parties were subjected to cross‑examination, the truth would be more readily identifiable. However, when cross‑examination is unavailable, the task of weighing opposing affidavits becomes considerably more difficult for the adjudicating authority. In such circumstances the Court is required to examine which side the balance of probabilities favours and to scrutinise each affidavit with great critical attention in order to decide which version is more credible. Consequently, while determining a factual question on appeal, the Court normally gives considerable weight to the factual findings that the High Court recorded in the original proceedings.

Turning now to the substantive material presented by the parties, the Court examined the principal points raised by the narrative advanced by Ramakotaiah and considered how the conflicting versions were supported by the affidavits filed. In the present proceedings Ramakotaiah submitted the primary affidavits in which he alleged bias on the part of the Minister, while the Minister responded by filing two affidavits that were intended to back the statements made by Ramakotaiah on various aspects of the bias claim. All of these sworn statements had to be evaluated in order to resolve the central issue of alleged bias. A particularly significant allegation recorded by Ramakotaiah was that Bhujaiah had instructed him to meet the Minister, an instruction that, according to Ramakotaiah, was given on 18 August 1960. The factual backdrop revealed that Bhujaiah had met the Minister in Hyderabad on 16 August 1960, and, acting on the Minister’s request, he later saw Ramakotaiah at Narasaraopet in Guntur District. Ramakotaiah maintained that Bhujaiah was a relative of the Minister and that his visit to the Minister was motivated by the desire to secure admission for his eldest son in Kakinada Medical College. According to Bhujaiah’s own affidavit, he had made a donation of Rs. 7,020 to the college on the Minister’s advice in order to obtain the desired admission for his son, and this purpose explained his meeting with the Minister on 16 August. Two crucial questions emerged from this portion of the story, and they required careful examination by the Court. First, whether Bhujaiah was, even if only distantly, related to the Minister, and second, whether Bhujaiah could legitimately have approached the Minister for the purpose that he described. The evidence indicated that Bhujaiah was a person of some standing and that the Minister had made no allegation that Bhujaiah was hostile or that the Minister possessed any motive to fabricate a false affidavit against him. In his affidavit Bhujaiah described the relationship in a convoluted manner, stating, “My aunt’s brother‑in‑law and the Hon’ble Minister married daughters of brothers.” Ramakotaiah reproduced a similarly elaborate description of the same familial connection in his own affidavit, using comparable language to that employed by Bhujaiah. These statements, when interpreted, imply that the Minister’s wife’s cousin’s husband was Bhujaiah’s uncle, thereby establishing a remote familial connection.

The Court observed that the relationship described by Bhujaiah placed the Minister’s uncle as Bhujaiah’s uncle, a connection that was undeniably remote. The High Court focused on the way the Minister attempted to repudiate this claim. In the affidavit dated 12 December 1960 the Minister asserted that he did not even know Bhujaiah. When the alleged kinship was later highlighted, the Minister filed an additional affidavit on 10 January 1961 in which he declared that he could neither accept nor reject the relationship advanced by Bhujaiah. In the same affidavit the Minister elaborated that “the relationship even as mentioned by him is so very remote and far‑fetched, namely, that my wife’s father’s brother’s daughter’s husband is the brother‑in‑law of Bhujaiah’s aunt. Whether it is paternal or maternal aunt is not stated or known.” The Court noted that, although the Minister emphasized the distance of the claimed connection, he did not positively assert that no relationship existed at all. If the purported link ran through the Minister’s wife, the Minister could have consulted his wife or her relatives to determine whether Bhujaiah was related to her. Given the seriousness of the allegation, the Court held that the Minister ought to have investigated the matter and responded to Bhujaiah’s statement in a more decisive manner. Moreover, the Court found it difficult to accept the Minister’s claim that he was unable to either deny or confirm the relationship, characterizing the stance as evasive. The High Court’s view was that the Minister’s explanation was unsatisfactory, a view with which the Court agreed.

The Court then turned to the issue of why Bhujaiah purportedly met the Minister in Hyderabad. The Minister’s denial was framed in technical terms. He asserted that, as Education Minister, he did not have charge of medical colleges or their admissions, that he had no involvement with the medical college in question, and that the matter lay outside his portfolio. Consequently, it was suggested that Bhujaiah could not have seen him. The Court found this response inadequate because Bhujaiah’s allegation was specific and did not hinge on the Minister’s official responsibilities. Even if the Minister was not responsible for the medical college, the Court held that it was not unreasonable to infer that a man who was related to the Minister and who had paid a donation of Rs 7,020 to secure admission for his son might seek a meeting with the Minister in the hope of obtaining assistance. Therefore, the Court concluded that two material facts concerning the first significant allegation made by Ramakotaiah were effectively established, and that the Minister’s denial on this point was unconvincing.

The Court found that the Minister’s explanation concerning his alleged lack of responsibility for the matters raised did not satisfy the requirements of a satisfactory answer. The next significant episode in the narrative presented by Ramakotaiah related to a trunk telephone call that he claimed to have placed to the Minister on 19 August. Regarding this allegation, the Court observed that the Minister’s manner of responding through his counter‑affidavits was far from adequate. In his first counter‑affidavit, the Minister attempted to repudiate the entire account of the trunk call. In response, Ramakotaiah produced a telephone bill concerning the call in question. The bill demonstrated that a trunk call had indeed been initiated on 19 August, with the booking time recorded at 6:27 a.m. and the actual connection occurring at 7:23 a.m. The call was identified as a pay‑per‑call type, the recipient being the Minister himself, and the total duration of the call was three minutes. The Minister suggested that the call might not have been placed by Ramakotaiah personally but rather by one of the other partners of the firm. Ramakotaiah countered this suggestion by submitting an affidavit that established that, at the relevant time, only he was in a position to have placed the trunk call, thereby effectively rebutting the Minister’s speculation. Subsequently, the Minister asserted that the mere fact that a trunk call had been booked to his number did not necessarily mean that Ramakotaiah had spoken directly with the Minister. He proposed that Ramakotaiah might have been connected with the Minister’s personal assistant instead. The Court noted that the call was connected at 7:23 a.m.; therefore, if the Minister’s contention was that his personal assistant or another family member had answered the call and that he himself was unaware of its contents, the Minister could have produced an affidavit from the personal assistant or any other individual who received the call. The argument that the Minister received so many trunk calls daily that he could not specifically deny this particular call was not found to be a satisfactory response by the High Court, and the present Court agreed with that view. It was further observed that, among the seven shareholders of the respondent company, Ramakotaiah alone was a permanent resident of Narasaraopet, making it extremely unlikely that he would have booked a trunk call to the Minister’s Hyderabad number without intending to speak directly with the Minister. Moreover, the call lasted three minutes, indicating that a conversation must have taken place between the two parties connected by the trunk call. Because the Minister’s affidavits concerning this matter were judged to be unsatisfactory, the Court held that the evidence establishing that Ramakotaiah had booked a trunk call to the Minister’s number corroborated Ramakotaiah’s version of events to that extent. The Court then turned to the subsequent issue of whether Ramakotaiah had actually seen the Minister on 26 August.

In this matter, the Court examined the claim that Ramakotaiah travelled to Hyderabad on 26 August 1960. The claim was supported by the sworn statements of five individuals—Anjaneyulu, Venkateshwarulu, Kasi Rama Rao, Basivi Reddi and Adinarayana. The Minister contested the allegation and asserted that no meeting with Ramakotaiah occurred on that date. However, the affidavit of Adinarayana provided a contrary narrative, stating that on 26 August he was waiting inside the Minister’s private chamber with the purpose of meeting the Minister in connection with the Congress elections. According to Adinarayana, both the Minister and Ramakotaiah emerged from the Minister’s room at that time, indicating that a direct encounter took place. The principal contention raised by the Minister’s side was that it was highly unlikely for Ramakotaiah to defer a meeting with the Minister until 26 August after having received a message from Bhujaiah on 18 August and after a telephone conversation on 19 August in which the Minister allegedly instructed Ramakotaiah to meet him in Hyderabad for a personal discussion concerning the elections. The Court responded that the election was scheduled for 28 August, and that members of the Andhra Pradesh Congress Committee, who were dispersed across the state, were not expected to convene for a collective meeting prior to 26 August. Consequently, the timing of the meeting corresponded with the practical requirements of the electoral campaign. Moreover, the Court noted that after the encounter on 26 August, Ramakotaiah proceeded to solicit support from his five friends on both 26 and 27 August, an activity that is typical of intensive canvassing undertaken on the eve of an election. Therefore, the Court concluded that there was no logical basis to deem Ramakotaiah’s decision to wait until 26 August as implausible or to reject the credibility of his account of meeting the Minister on that day.

The next segment of the dispute concerned Ramakotaiah’s attempts to obtain votes for the Minister from the five friends previously identified. This portion of the narrative rested upon Ramakotaiah’s own affidavit together with the affidavits of Anjaneyulu, Venkateshwarulu, Kasi Rama Rao and Basivi Reddi. All four individuals were, without dispute, members of the Andhra Pradesh Congress Committee at the relevant time and each of them recounted a conversation they had with Ramakotaiah at the Royal Hotel. Their statements were mutually consistent and, for the most part, corroborated the version presented by Ramakotaiah. While the affidavits did not explicitly state that Ramakotaiah had disclosed a specific request from the Minister to secure their votes, the collective testimony nevertheless supported the core elements of his story, namely that he had met the friends, discussed electoral matters, and sought to influence their voting intentions in favor of the Minister. The Court therefore regarded these affidavits as substantive evidence that reinforced the overall credibility of Ramakotaiah’s account concerning his canvassing efforts during the critical period preceding the election.

The Court observed that the material tended to show that Ramakotaiah did not seek to embarrass the Minister and that, of his own volition, he was eager to assist the Minister whenever possible. The Court further noted that no party alleged that Ramakotaiah was a partisan of the power group or that he had attempted to persuade the members to vote for the power group on his own behalf. Consequently, only one remaining element of Ramakotaiah’s narrative required examination – the alleged threat made by the Minister when Ramakotaiah informed the Minister that he had been unable to fulfil the requested task. On this point, the record contained an affidavit submitted by Ramakotaiah and a categorical denial of the alleged threat by the Minister. In reviewing the various aspects of Ramakotaiah’s story, the High Court examined the affidavits filed by both sides and repeatedly criticised the evasive nature of the Minister’s affidavits. The High Court specifically told the Advocate‑General representing the appellants that it was not satisfied with the Minister’s evasive statements and appeared to expect the Minister to file additional affidavits; however, no further affidavit was filed and the matter had to be decided on the affidavits already on record. The Supreme Court carefully considered every argument presented by the learned Solicitor‑General who contended that the High Court’s finding was erroneous. After thorough examination, the Court found no basis on which it could set aside the High Court’s conclusion. As previously indicated, the question before the High Court was confined to a narrow issue – namely, the credibility of the affidavits filed by the parties. In view of the substantial volume of affidavit evidence submitted on behalf of Ramakotaiah and the unsatisfactory character of the Minister’s affidavits, the High Court was not inclined to accept the Minister’s denial. Even allowing for the possibility that Ramakotaiah might have been embittered by the Minister’s decision, it remained difficult to conclude that the High Court was wrong in finding that the narrative advanced by Ramakotaiah regarding bias on the part of the Minister had been established. The individuals who executed affidavits supporting Ramakotaiah’s case were all persons of standing, and no allegation was made that they were hostile to the Minister or possessed any motive to fabricate false statements. Having given painstaking consideration to the entire evidence and to the points raised by the learned Solicitor‑General, the Court concluded that there was no ground for interfering with the High Court’s finding.

Having examined the materials placed before it in support of the appeals, the Court determined that the appellants had not demonstrated a sufficient ground upon which the Court could validly disturb the findings and conclusions reached by the High Court. The assessment of the evidence and the arguments presented led the Court to the conclusion that no case existed that would justify an intervention in the High Court’s adjudication. Accordingly, the Court held that the proper result was to reject the appeals. The appeals were therefore dismissed. In addition to dismissing the appeals, the Court ordered that the parties seeking the appeals should bear the costs of the proceedings. The costs order specifically included an award for one set of hearing fees, which the Court directed to be payable by the appellants. This disposition reflected the Court’s view that the appeals did not warrant further consideration and that the appellants should bear the financial consequences of their unsuccessful attempt to obtain relief.