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2026 Supreme(Online)(Kar) 19919
THE HIGH COURT OF KARNATAKA
S.G. Pandit, K. V. Aravind, JJ
M.P. Ravikumar – Appellant
Versus
State of Karnataka – Respondent
WP No. 18849 of 2025 | WP No. 6390 of 2026
For the Appellants/Petitioners: Raghavendra G. Gayatri
For the Respondents: B. Ravindranath
Failure to comply with court-ordered timelines for disciplinary proceedings, absent bona fide reasons and a timely request for extension, renders subsequent extensions impermissible and risks the loss of jurisdiction by the disciplinary authority, undermining the rule of law.
Headnote:(A) Constitution of India - Articles 226 and 227 - Service Law - Disciplinary Proceedings - Delay in compliance with judicial orders - Tribunal directed completion of disciplinary proceedings within two months - Respondents failed to comply and filed for extension after significant delay - Extension granted by Tribunal despite its own earlier order prohibiting further extension - Held, disregard for judicial timelines erodes the dignity of the judicial process - Disciplinary Authority ceases to have jurisdiction if proceedings are not completed within the time prescribed by a court/tribunal without a valid, bona fide reason for delay - Extension application without justification is impermissible. (Paras 3.1, 7.8, 8.1, 8.2, 9)
Facts of the case:
The petitioner, a Surveyor, challenged disciplinary proceedings before the Tribunal. The Tribunal set aside the penalty on 03.09.2024, directing completion of the inquiry within two months. The respondents failed to comply, and after an inordinate delay, the Tribunal, on 13.02.2026, permitted an extension of time, which was subsequently challenged in these writ petitions.
Findings of Court:
The Court held that the explanation for the delay provided by the respondents was a "bureaucratic excuse" lacking bona fides. It emphasized that failure to comply with court-ordered timelines undermines the rule of law and that the Tribunal erred in granting an extension after explicitly barring such requests earlier.
Issues: Whether the Tribunal was justified in granting an extension of time for completion of disciplinary proceedings despite a previous order prohibiting further extensions and the absence of bona fide reasons for the inordinate delay.
Ratio Decidendi: Where a court or tribunal prescribes a fixed timeline for disciplinary proceedings with a default condition, the Disciplinary Authority loses jurisdiction upon the expiry of that period. Extensions can only be granted upon showing genuine and sufficient cause before the lapse of the period, and failure to do so, coupled with lack of bona fides, justifies interference by the Writ Court.
Result: Writ Petitions allowed.
| Table of Content |
|---|
| 1. procedure for handling interconnected writ petitions. (Para 1 , 2) |
| 2. history of disciplinary proceedings and tribunal orders. (Para 3) |
| 3. contentions regarding delay in complying with mandate. (Para 4 , 5) |
| 4. court's disapproval of bureaucratic delays. (Para 7) |
| 5. judicial rigor in enforcing compliance deadlines. (Para 8 , 9) |
THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO ISSUE A WRIT OF CERTIORARI AND SET ASIDE THE ORDER OF THE HONBLE KSAT IN A.No-927/2024 PASSED ON 03.09.2024 IN SO FAR AS NOT GRANTING ANY RELIEF RELATING TO THE PRAYER No-1 AND 2 AND ALLOW THE ABOVE WP AS PRAYED FOR.
THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO a) ISSUE A WRIT OR ORDER IN THE NATURE OF CERTIORARI OR ANY OTHER WRIT QUASHING THE IMPUGNED ORDER OF THE HONBLE TRIBUNAL DATED 13/02.2026 IN A.NO.927/2024 (VIDE ANNEXURE-A) AND CONSEQUENTLY DISMISS THE INTERIM APPLICATION viz., IA II DATED 09/01/2025 (VIDE ANNEXURE-L).
THESE PETITIONS, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER:
CORAM: HON'BLE MR. JUSTICE S.G.PANDIT and HON'BLE MR. JUSTICE K. V. ARAVIND
ORAL ORDER
(PER: HON'BLE MR. JUSTICE K. V. ARAVIND)
Heard Sri Raghavendra G. Gayatri, learned counsel for the petitioner, and Sri B. Ravindranath, learned Additional Government Advocate for the respondents, in both the petitions.
2. These petitions, involving common questions of fact, are interconnected; accordingly, they are disposed of by this common order.
3. While the petitioner was working as a Surveyor in the Office of the Assistant Director of Land Records, K.K. Pura, a complaint came to be lodged alleging that he had prepared a bogus sketch pertaining to land in Sy. No. 10 of Heggadagere Village, Bidadi Hobli, Ramanagara Taluk. Pursuant thereto, a show-cause notice was issued and an enquiry was initiated.
3.1 The petitioner challenged the articles of charge by filing Application No. 927/2024 before the Tribunal. The Tribunal, by order dated 03.09.2024, noticing that the enquiry report had concluded that the charges against the petitioner stood proved and that a show-cause notice had been issued, set aside the order of penalty on the ground that the reply filed by the petitioner had not been considered. The Disciplinary Authority was directed to pass a final order within a period of two months. The Tribunal further clarified that the proceedings shall be completed within the stipulated period without seeking any extension of time.
3.2 The said order is assailed in W.P. No. 18849/2025. In the meanwhile, the respondent-Authorities filed an application before the Tribunal seeking extension of time. The Tribunal, by order dated 13.02.2026, extended the time for compliance of its earlier direction dated 03.09.2024 by six weeks. The said order of extension is impugned in W.P. No. 6390/2026.
3.3 In the interregnum, the Disciplinary Authority, in purported compliance of the Tribunal’s direction, passed a final order dated 26.02.2026 imposing the penalty of withholding four annual increments with cumulative effect.
4. Sri. Raghavendra G. Gayatri, learned counsel appearing for the petitioner, submits that though the Tribunal, by order dated 03.09.2024, had granted two months’ time for passing a fresh order of penalty, the Disciplinary Authority failed to pass any order until 26.02.2026. It is further submitted that the application seeking extension of time was filed only on 08.01.2026, well beyond the stipulated period.
4.1 Learned counsel contends that no justifiable reasons were assigned in the application seeking extension of time and that the reasons, in any event, lack bona fides. It is urged that the Tribunal, without properly considering the grounds urged in the application, has erred in granting extension of time. It is also pointed out that in its earlier order dated 03.09.2024, the Tribunal had categorically observed that no further extension of time
