Service Law — Disciplinary Proceedings — Judicial Review — Remand by High Court — Impermissibility of Deciding on Single Point
(Paras 8–10)
Where several substantial issues arise in a writ petition challenging disciplinary action, the High Court must adjudicate all material issues with reasons.
Remanding a matter solely on one procedural aspect (authorization to initiate proceedings) without examining:
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Alleged breach of principles of natural justice,
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Legality of inquiry proceedings,
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Correctness of Tribunal’s findings,
constitutes a fundamental flaw vitiating the order.
Judicial Discipline — Duty to Record Findings on All Issues
(Para 9)
It is settled law that when multiple issues arise, the Court must:
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Record findings on each issue,
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Assign reasons,
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Avoid selective adjudication on a single decisive point.
Such an approach ensures clarity, finality, and assists appellate review.
Disciplinary Proceedings — Natural Justice — Denial of Cross-Examination
(Paras 5, 8)
Where employee alleges:
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Closure of inquiry mid cross-examination,
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Denial of opportunity to cross-examine prosecution witnesses,
such allegations go to the root of fairness and must be examined by the writ court before remand.
Superannuation — Relief — Reinstatement Infructuous
(Para 11)
Upon employee reaching age of superannuation:
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Reinstatement becomes academic,
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Surviving issues are:
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Justification of Tribunal’s interference,
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Entitlement to back wages,
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Entitlement to retiral benefits.
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FACTUAL MATRIX
Tribunal Stage
The School Tribunal, Nagpur (8 August 2019):
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Set aside dismissal order,
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Granted reinstatement with consequential benefits.
High Court Stage
Bombay High Court (Nagpur Bench)
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Allowed writ petition filed by management (5 September 2024).
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Quashed Tribunal’s order.
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Remanded matter to Tribunal.
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Considered only one issue:
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Whether Secretary was authorized via resolution to initiate disciplinary proceedings.
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No consideration was given to:
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Alleged breach of natural justice,
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Cross-examination issues,
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Merits of Tribunal’s findings.
Review petition rejected on 25 September 2024.
ISSUES BEFORE THE SUPREME COURT
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Whether High Court erred in remanding matter based on a solitary procedural issue?
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Whether High Court was required to adjudicate all substantial issues?
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What relief survives post-superannuation?
ANALYSIS
I. Selective Adjudication — A Jurisdictional Error
The Supreme Court held that the High Court:
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Focused exclusively on authorization of Secretary,
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Ignored substantive grounds challenging disciplinary inquiry,
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Failed to evaluate whether principles of natural justice were violated.
Such selective adjudication renders the decision legally unsustainable.
II. Denial of Cross-Examination — Root Violation
Appellant contended:
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Cross-examination of main management witness was ongoing on 31 July 2017.
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Inquiry officer abruptly closed proceedings on 1 August 2017.
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Opportunity to cross-examine remaining witnesses denied.
These allegations:
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Strike at the core of fair hearing,
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Engage audi alteram partem,
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Required judicial examination.
High Court omitted consideration of these material aspects.
III. Doctrine of Comprehensive Issue Determination
Para 9 articulates an important judicial principle:
Courts must answer each issue arising in the case with reasons rather than focusing on a single decisive point.
Rationale:
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Protects litigant’s right to reasoned justice,
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Prevents piecemeal adjudication,
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Assists appellate scrutiny,
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Promotes judicial discipline.
IV. Superannuation — Shift in Relief
Since appellant attained superannuation:
Reinstatement no longer survives.
High Court must now determine:
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Was Tribunal justified in interfering with disciplinary action?
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Is appellant entitled to back wages and retiral benefits?
RATIO DECIDENDI
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A High Court commits a fundamental adjudicatory error when it decides a writ petition on a single procedural issue while ignoring other substantial issues.
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Allegations of breach of natural justice in disciplinary proceedings must be examined before remanding.
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Reasoned findings on all material issues are mandatory for judicial legitimacy and appellate efficacy.
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Upon superannuation, reinstatement becomes infructuous; entitlement shifts to monetary and retiral consequences.
