Park v. Brahmbhatt (2020)

Citation: Park v. Brahmbhatt (2020)
Parent Document: Park v. Brahmbhatt (2020)
Jurisdiction: DC (municipal)
Effective Date: 2020-08-13
Original Source: https://www.courtlistener.com/opinion/4774864/park-v-brahmbhatt/ ↗

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           We do not address whether the EBC, an investigative arm of the World
Bank, is itself a quasi-judicial body. The trial court did not analyze this precise
question as to the EBC and the WBAT individually; it looked to the “structure”
and “administrative apparatus” of the Bank to find that “[t]he administrative
process, seen as a whole, is clearly quasi-judicial.” Although we agree that the
administrative apparatus and structure of the Bank are relevant, it would have been
preferable to make a specific determination as to whether each body was a quasi-
judicial tribunal. Such a determination can make a difference where, for example,
a party submits a defamatory statement to an investigatory body (like the EBC),
and invokes future proceedings before a quasi-judicial body (like the WBAT) as a
sham rationale for the submission. We do not think the present case presents such
a situation, however.
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