Silva and Others vs. Director of Health Services and Others – sllr 2010 volume 1 page 285
In the case between Silva and Others (Public Health Inspectors) and the Director of Health Services and Others, the court addressed whether recommendations by the Human Rights Commission—specifically regarding the removal of the supervisory function of Public Health Inspectors (PHIs) over Public Health Field Officers (PHFOs)—possess immediate legal effect and can be enforced or quashed by a writ of certiorari. The application was prompted by the issuance of an administrative circular implementing the Commission’s recommendation. It was held that the Commission’s recommendations do not take effect by themselves, lack statutory force for direct enforcement or certiorari review, and that altering duties of PHIs fell within the administrative authority of the Director General of Health Service

