Dilrukshi Dias Wickramasinghe vs Hon. Upaly Abeyrathne, Chairman, PCoI – SC FR APPLICATION NO 33/2021-2025

The court addressed the legality and procedural validity of inquiries conducted by a Presidential Commission of Inquiry. It was held that the Commission had unlawfully entertained complaints beyond its statutory authority and failed to adhere to mandatory procedural requirements and natural justice, resulting in the infringement of the petitioner’s rights under Article 12(1) of the Constitution. The key principle reaffirmed is that actions of a Presidential Commission of Inquiry must comply with statutory mandates and natural justice, and that ultra vires actions by such commissions are subject to judicial review. Reliance was placed on the Constitution and the Commissions of Inquiry Act, underlining the requirement for procedural fairness and statutory compliance by public authorities.