Search Blog

Monday, April 29

Court/Tribunal must remit case to disciplinary authority if enquiry is vitiated - Supreme Court


Shri Anant R. Kulkarni vs. Y.P. Education Society & Ors, Civil Appeal No. 3935 of 2013 (Decided on 26.04.2013)


The Court examined following question:

“In case the punishment is set aside by the Court/Tribunal as the enquiry stood vitiated for technical reasons, whether the employer is entitled to hold the enquiry afresh from the point it stood vitiated?

The Court held:

It is a settled legal proposition that, once the Court set asides an order of punishment on the ground, that the enquiry was not properly conducted, the Court should not severely preclude the employer from holding the inquiry in accordance with law. It must remit the concerned case to the disciplinary authority, to conduct the enquiry from the point that it stood vitiated, and to conclude the same in accordance with law. However, resorting to such a course depends upon the gravity of delinquency involved. Thus, the court must examine the magnitude of misconduct alleged against the delinquent employee. It is in view of this, that courts/tribunals, are not competent to quash the charge-sheet and related disciplinary proceedings, before the same are concluded, on the aforementioned grounds.” [Para 7]

The Court quoted following case law

Managing Director, ECIL, Hyderabad etc. v. B. Karunakar etc.etc. AIR 1994 SC 1074;

Hiran Mayee Bhattacharyya v. Secretary, S.M. School for Girls & Ors., (2002) 10 SCC 293;

U.P. State Spinning C. Ltd. v. R.S. Pandey & Anr., (2005) 8 SCC 264; and

Union of India v. Y.S. Sandhu, Ex-Inspector AIR 2009 SC 161)


For Full text follow the link: