High Court Slams Haryana Govt for "Anguishing" Disciplinary Action Against Doctor, Orders Issuance of NOC for PG Course

Chandigarh: The Punjab and Haryana High Court has strongly rebuked the State of Haryana for withholding a No Objection Certificate (NOC) from a government doctor seeking to pursue a post-graduate degree, based on a pending disciplinary inquiry initiated because he did not stand up for a visiting MLA while on emergency duty.

In a scathing judgment dated November 21, 2025, a division bench of Justice Ashwani Kumar Mishra and Justice Rohit Kapoor termed the state's action "highly disturbing" and "manifestly arbitrary." The court not only ordered the immediate issuance of the NOC but also imposed a cost of ₹50,000 on the State, payable to the Poor Patient Welfare Fund at PGIMER, Chandigarh.

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Background of the Case

The petitioner, Dr. Manoj, a Casualty Medical Officer with the Haryana government, had secured the requisite marks for admission into a Post-Graduate (PG) medical course. To apply as an in-service candidate, he required an NOC from his employer, the State of Haryana.

The state refused to grant the certificate, citing pending disciplinary proceedings against him under Rule 8 of the Haryana Civil Services (Punishment and Appeal) Rules, 2016, which deals with minor punishments.

The "Offence": Failure to Stand for an MLA

The disciplinary action stemmed from an incident during the COVID-19 pandemic. While Dr. Manoj was on duty in the emergency ward of a government hospital, a local Member of the Legislative Assembly (MLA) visited the premises. Annoyed that the doctor did not rise from his seat upon his arrival, the MLA's visit led to the issuance of a Show Cause Notice (SCN) to the petitioner.

In his reply submitted in June 2024, Dr. Manoj explained that his failure to stand was unintentional as he did not recognize the MLA and that it did not constitute discourtesy, especially while attending to his duties in an emergency setting. Despite this explanation, the state government kept the proceedings pending without passing a final order, effectively blocking the doctor's academic aspirations.

Court's Stern Observations

The High Court expressed its profound dismay at the state's conduct, highlighting the insensitivity of penalizing a medical professional for such a trivial reason. The bench observed:

> "We are anguished and amazed at the action of the State in issuing the SCN to a Government Doctor who was on emergency duty during the COVID-19 period only because he did not rise when the MLA arrived. To expect a doctor to rise when an MLA enters the emergency ward of the hospital and to propose disciplinary action against him if he does not rise is highly disturbing."

The court emphasized the rigorous journey of medical professionals and the need for public representatives to show them respect rather than subject them to arbitrary actions. It noted that the doctor's explanation was completely ignored and that using such pending proceedings to deny him an opportunity for higher education was unjust.

> "It would be wholly unjust and manifestly arbitrary to allow adverse action against a Doctor merely because he did not rise upon the arrival of an MLA. Keeping such proceedings pending for years and denying the petitioner an NOC on such basis, therefore, cannot be sustained," the Court stated.

Final Verdict and Implications

Finding the state's actions entirely unsustainable, the High Court allowed the writ petition filed by Dr. Manoj. The judgment serves as a significant precedent against the misuse of administrative power and underscores the judiciary's role in protecting professionals from arbitrary and vexatious disciplinary actions, particularly when such actions impede their career and educational advancement.

The court directed the State of Haryana to issue the NOC to the petitioner "forthwith," clearing the path for his post-graduate studies and sending a strong message about the importance of respecting dedicated medical professionals.