- The Govt. did not record any reason in writing for being satisfied that the strict application of any rule would cause undue hardship — The order of relaxation made in respect of respondents declaring them appointed under rules is unlawful and without any jurisdictional competence particularly when the order for all the appointees has been made in bulk. Sadaqat Hussain Shah & 4 others v. AJ&K Govt. & 3 others 1999 SCR 145 (B)