In Ganayutham’s case AIR 1997 SC 3387 the Supreme Court clarified the scope of the rule of proportionality as a basis for judicial review. In view of the importance of that decision for structuring administrative discretion, we reproduce the relevant portions from that judgment. The powers exercisable by the Central Government or the Regional Director or the Registrar under relevant provisions of the Companies Act (illustratively speaking proceedings u/Sections 20, 22, 35, 132, 203, 235, Chapter IVA proceedings, S. 396) may give rise to occasions for judicial review involving recourse to Wednesbury or the CCSU principles. Hence the propositions of law set out by the Supreme Court in Ganayutham are of interest to students of company law too. The position of “proportionality” in administrative law in England and India can be summarised as follows  To judge the validity of any administrative order or statutory discretion normally th ....