The case of Boesche v. Udall in 1962 revolved around the issue of oil and gas leases on public lands. The Secretary of the Interior, Stewart Udall, had cancelled a lease held by Fred A. Boesche due to an alleged violation of statutory requirements for obtaining such a lease. The Supreme Court ruled in favor of Udall, stating that he was within his rights to cancel the lease as it was obtained through fraud or error under Section 31(a) and (b) Mineral Leasing Act for Acquired Lands which allows cancellation if there is any misrepresentation or failure to comply with regulations during application process. This decision upheld the power and authority vested in administrative agencies like Department Of Interior over public resources management.

In the dissenting opinion for Boesche v. Udall, Justice Douglas argued that the Secretary of Interior's decision to cancel oil leases due to a procedural error was an overreach of power and violated principles of fairness. He contended that the lessee should have been given notice and opportunity to correct any deficiencies before cancellation occurred. Furthermore, he believed that this case represented a dangerous precedent where administrative agencies could arbitrarily void contracts without proper process or consideration for individual rights. He also pointed out inconsistencies in how similar cases were handled by different departments within government, suggesting a lack of uniformity in policy application which further undermined justice and equity.