Court Affirms AAI's Authority in Aviation Safety Matters, Sets Aside Judgment on Procedural Grounds
In a significant ruling, the Delhi High Court has upheld the Airports Authority of India's (AAI) technical determinations regarding the permissible height of Shristi Infrastructure Development Corporation Ltd.'s Tower-II near Netaji Subhas Chandra Bose International Airport in Kolkata. The judgment, delivered by a division bench comprising Justices Anil Kshetarpal and Harish Vaidyanathan Shankar, set aside a previous decision that labeled AAI's communication as unreasoned and procedurally defective.
The case centered around Shristi Infrastructure's challenge to an AAI communication dated March 8, 2019, which restricted the height of Tower-II due to safety regulations under the 2015 Notification. Shristi Infrastructure argued that the decision was based on a "crude method" without proper mathematical modeling, and contended that their structures did not form a "large object" as per regulatory definitions.
The High Court, however, reaffirmed the principle that courts should defer to the technical expertise of statutory bodies like AAI, especially in safety-critical areas such as aviation. The judgment emphasized that judicial review in such technical matters is limited to ensuring adherence to statutory mandates and avoiding arbitrariness or procedural illegality.
While upholding AAI's technical findings, the court acknowledged the procedural fairness in AAI's decision-making process, noting that the communication in question was part of a structured evaluative process with substantial expert input. The court found that the reasons behind AAI's decision were discernible from the overall record, despite the communication itself being brief.
The bench also addressed Shristi Infrastructure's reliance on a private expert report by Sakthi Aviation, stating that such reports do not hold binding authority over statutory decisions. The court emphasized that private expert opinions, while potentially relevant, cannot override the determinations of a competent statutory body unless proven irrational or tainted.
In conclusion, the court allowed AAI's appeal, reinstating the communication dated March 8, 2019, while dismissing Shristi Infrastructure's appeal challenging the technical assessments. The judgment reinforces the judiciary's role in balancing deference to expert agencies with the necessity of procedural fairness, especially in domains involving public safety and technical expertise.
Bottom Line:
Judicial review in technical matters is limited to ensuring adherence to statutory mandates, natural justice, and avoidance of arbitrariness or irrationality. Courts should defer to the technical expertise of statutory bodies unless the decision is arbitrary or procedurally defective.
Statutory provision(s): Aircraft Act, 1934, Height Restrictions for Safeguarding Aircraft Operations Rules, 2015, Principles of Natural Justice.
