Analyze the legal validity of administrative appointments made by a former president but not delivered before a new president took office, using case law.

The central legal issue is the validity and effectiveness of administrative appointments made by a former president (President Loco) that were formally approved, signed, and sealed, but not delivered to the relevant executive institutions before a new president (President Cassava) took office. This raises questions about when an administrative act becomes legally complete and binding, and the impact of a change in executive leadership on uncompleted acts.

For an administrative act, such as an appointment, to be legally effective and create vested rights for the appointees, it generally requires more than just internal approval or signing. The act must be communicated or delivered to the affected parties or the relevant institutions. Until such communication, the act may be considered inchoate or incomplete.

• Formal Steps vs. Efficacy: While signing and sealing demonstrate the executive's intention and formal approval, the act's legal efficacy often depends on its public notification or delivery.
• Functus Officio: This doctrine states that once an official has made a final decision, they cannot revisit it. However, this applies only when the act is truly final and complete. If the act is incomplete (e.g., not delivered), the official or their successor may still have the power to alter or revoke it.
• Vested Rights: Appointees acquire a vested right to their positions only when the appointment process is fully completed, and they have been formally notified or have taken up the office. Without this, they typically have no legally enforceable right.

A seminal case illustrating this principle is:

• Marbury v. Madison (1803) 5 U.S. 137: In this landmark U.S. Supreme Court case, President John Adams had signed and sealed judicial commissions, but they were not delivered before President Thomas Jefferson took office. The Court, led by Chief Justice John Marshall, held that while the signing and sealing completed the President's act, the delivery of the commission was essential for it to be legally effective and for the appointee to have a vested right to the office. Without delivery, the appointment was not complete, and the new administration was not legally bound to deliver them. This case underscores that an administrative act, even if formally approved, may not be legally binding until communicated. Similar principles are often applied in Commonwealth jurisdictions, where the issuance and receipt of an appointment letter or gazetting of an appointment are crucial for its completion.

In the scenario, President Loco's appointments were approved, signed, and sealed. However, the critical fact is that they were never delivered to the appropriate institution of the executive. Following the principle established in Marbury v. Madison, the appointments, despite the formal steps taken, were not complete or effective in law. The appointees had not acquired vested rights to their positions because the administrative act was not finalized through communication or delivery.

Therefore, when President Cassava took office, the appointments made by President Loco were still inchoate. President Cassava, as the new head of the executive, had the authority to review and effectively revoke these uncompleted appointments. His order to halt them would likely be considered legally sound because the administrative process for those appointments had not reached its final, binding stage, and no vested rights had been created.

The legal principle rooted in this scenario is that: