While an investigative body may possess jurisdiction to report on corruption in service appointments, any subsequent disciplinary action against public servants requires adherence to the principles of natural justice and an independent enquiry, as the findings of an external body cannot override fundamental procedural due process.

JUDGMENT :

DEVASHIS BARUAH, J.

1. Heard Mr. C.T. Jamir, learned Senior counsel assisted by Mr. I. Imchen, learned counsel appearing on behalf of the Appellants in the present batch of writ appeals. Mr. N. Angami, learned Senior Government Advocate appears for the State of Nagaland.

2. The present batch of writ appeals have been filed challenging the common Judgment and Order dated 24.11.2025, passed in WP(C)/3/2025, WP(C)/17/2025 and WP(C)/18/2025.

3. We take up the appeals for disposal at the Admission stage itself.

BRIEF FACTS OF THE CASE

4. The Petitioners in WP(C)/3/2025 approached this Court challenging the proceedings initiated by the Nagaland Lokayukta in Complaint Case No. A-NLP-40/2022; the Order dated 16.07.2024 passed by the Nagaland Lokayukta, Nagaland; the Letter dated 26.07.2024 by the Nagaland Lokayukta Police, Nagaland; the Letter dated 20.12.2024 by the Joint Secretary to the Government of Nagaland, Labour & Employment, Skill Development & Entrepreneurship Department, in respect to the Petitioners as well as the Termination Order dated 07.01.2025 passed by the Director, Directorate of Labour & Employment Skill Development and Entrepreneurship, Nagaland, Kohima.

5. The challenge to the proceedings before the Nagaland Lokayukta by the Petitioners in WP(C)/3/2025 is on the basis that in view of Section 9 read with the Second Schedule of the Nagaland Lokayukta Act, 2017 the Nagaland Lokayukta could not have entertained such complaint and as such, the complaint, the Order as well as the Letters which have been issued by the Nagaland Lokayukta were put to challenge. Furthermore, as it was on the basis of the recommendation made by the Nagaland Lokayukta, the Petitioners in WP(C)/3/2025 were terminated, that too, without issuance of any Show Cause Notice. The termination Order dated 07.01.2025 was also put to challenge.

6. Upon filing of WP(C)/3/2025, the records reveal that the impugned Order of Termination dated 07.01.2025 was stayed by the learned Single Judge. It further appears that pursuant to the stay granted to the impugned Order of Termination, the Termination Order dated 07.01.2025, by which the Petitioners in WP(C)/3/2025 were terminated was withdrawn by the State of Nagaland. It further appears that immediately thereafter Show Cause Notices were issued to the Petitioners in WP(C)/3/2025 as to why the services of the Petitioners should not be terminated. These Show Cause Notices have been assailed by the writ Petitioners in WP(C)/3/2025 by filing another writ petition, being WP(C)/17/2025.

7. The writ Petitioners in WP(C)/18/2025 was also issued a Show Cause Notice on 22.01.2025 as to why the services of the said writ Petitioner should not be terminated as the Petitioner was appointed without following due process in terms. It was also mentioned that he Show Cause Notice was issued in pursuance to the recommendations made by the Nagaland Lokayukta and the Personnel & Administrative Reforms Department (P&AR).

DECISION OF THE LEARNED SINGLE JUDGE

8. The records reveal that all the three writ petitions were taken up together by the learned Single Judge and vide the impugned Judgment and Order dated 24.11.2025 in the three writ petitions, the learned Single Judge opined that the Nagaland Lokayukta had the j