Delhi High Court Questions Repeated Requests for Extension to Conclude Departmental Inquiry - 2026-01-27

Endless Delays: Delhi High Court Intervenes as Departmental Inquiry Stalls

The sanctity of court-mandated timelines remains at the forefront of judicial concern after the Delhi High Court recently scrutinized yet another request for an extension in a long-pending departmental inquiry. In a stark reminder of the judiciary's expectation of efficiency, the court refused to entertain an application that sought more time despite the respondent’s previous formal undertaking to conclude proceedings.

The Backdrop of the Dispute

The matter involves Petitioner Anil Kohli and the Union of India, stemming from a writ petition originally disposed of on July 16, 2024. At that time, the court had issued a clear directive: conclude the inquiry proceedings against the petitioner within a six-month window.

However, as the months passed, the inquiry remained incomplete. Respondent No. 2, seeking to push back the deadline yet again, filed the present application, citing that the process was "underway" and nearly finished. The respondents shifted the blame for the impasse onto the petitioner, alleging unnecessary demands for charge-sheet copies. Naturally, counsel for the petitioner contested this narrative, characterizing the application as the fourth in a series of delay-inducing requests.

A Broken Undertaking

What escalated this routine request into a matter of judicial concern was the history of the case. The court noted that a previous request for extension had been rejected on May 28, 2025. Following subsequent legal maneuvers—namely an appeal and a Review Petition—the respondents had specifically assured the court that the process would conclude within five weeks.

Justice Sanjeev Narula highlighted the gravity of this backtrack, noting that the order disposing of the review petition clearly recorded an undertaking that "under no circumstances further extension shall be sought."

Key Observations

The High Court’s frustration with the habitual seeking of extensions was evident throughout the order:

• "It is evident that the Applicant has, in fact, been repeatedly seeking extension of time."
• "It is also a matter of concern that by order dated 28th May, 2025, this Court had rejected an earlier application seeking extension of time."
• "The aforesaid order clearly records an undertaking on behalf of Respondent No. 2 that no further extension of time would be sought. Despite the same, Respondent No. 2 now contends that certain circumstances have arisen necessitating a further extension of time."

A Judicial Redirect

In a decisive procedural move, the court observed that the current application, while labeled under Section 151 of the Code of Civil Procedure, was in substance an attempt to re-litigate a review order. Consequently, rather than granting the extension, Justice Sanjeev Narula directed the matter to be listed before the bench of Hon’ble Ms. Justice Jyoti Singh on February 10, 2026.

Implications for Future Cases

This order serves as a stern warning against treating court-mandated deadlines as flexible guidelines. By forcing the matter back before a specific bench, the Court has signaled that it will not tolerate the "revolving door" of extension requests, especially when those requests defy prior, solemn undertakings made to the justice system. For public departments, this serves as a critical reminder that departmental inquiries must not be weaponized through administrative delay at the expense of a petitioner's right to a timely resolution.