P. Rammohan Rao vs K. Srinivas 2025 INSC 212 - Administrative Law - Functus Officio

Principle of functus officio - Rule-making power of the legislature cannot be curtailed or nullified by application of the concept of functus officio. The principle of functus officio normally applies to a judicial forum or a quasi-judicial authority and would have no application to the rule-making authority which is within the domain of the State Government by virtue of Article 245 of the Constitution of India. (Para 42-3)

Administrative Law - Administrative actions and statutory rules that impact citizens’ rights are subject to judicial review, the notion that the State must provide a prior hearing to affected individuals during the exercise of its rule-making power is fundamentally flawed- If the State Government is compelled to afford an opportunity of hearing to every individual or entity likely to be affected by its administrative decision-making, it would effectively paralyze governance by imposing an undue procedural roadblock. This would place the State in a position where its rule-making authority would be severely constricted, defeating the very purpose of efficient policy implementation and undermining its ability to discharge its administrative duties. (Para 45-47)