In Baidyanath Mohapatra v. state of Orissa, the Supreme Court quashed the order of the tribunal confirming premature retirement on the ground that the chairman of the tribunal was also a member of the review committee which had recommended premature retirement. Which of the following legal maxim was used by Supreme Court while deciding the petition?

Nemo Debet Esse Judex in Propria Sua Causa Nemo debt non quad habit Qui Facit Per Alium, Facit Per Se Res Judicata Accipitur Pro Veritate

Nemo Debet Esse Judex in Propria Sua Causa

Nemo Debet Esse Judex in Propria Sua Causa: It means no one should be made a judge in his own cause. It is popularly known as the rule against bias. That is the authority sitting in judgment should be impartial and act without bias. If a judge or adjudicating authority is biased either in favour of one party or against the other, he cannot be expected to do justice in the matter. Such a person is disqualified from adjudicating and since such proceedings stand vitiated, any decision taken by him is liable to be set aside. This basic rule applies to all judicial authorities as well as to all administrative authorities who are required to act judicially or quasi-judicially. The rule is of wide application and means that a judicial or quasi-judicial authority should not only himself not be a party but must also not be interested as a party in the subject matter of the dispute which he has to decide. In Baidyanath Mohapatra v. state of Orissa, the Supreme Court quashed the order of the tribunal confirming premature retirement on the ground that the chairman of the tribunal was also a member of the review committee which had recommended premature retirement.