SupremeToday Landscape Ad
Back
Next
Judicial Analysis Court Copy Headnote Facts Arguments Court observation
Listen Audio Icon Pause Audio Icon
judgment-img

2026 Supreme(Online)(Mad) 24543

IN THE HIGH COURT OF JUDICATURE AT MADRAS
Mumminenni Sudheer Kumar, J
Dr.A.Renganathan – Appellant
Versus
The Registrar Gandhigram Rural Institute (Deemed to be University) – Respondent
W.P.(MD) No.5838 of 2026



Advocates:
For the Appellants/Petitioners: Mr.A.Renganathan Party-in-Person
For the Respondents: Mr.N.S.Karthikeyan, Mr.B.Babu

Disciplinary proceedings must respect natural justice principles and complete inquiries to ensure validity of show cause notices.

Headnote:In a disciplinary proceeding, the petitioner challenged a show cause notice under the CCS (CCA) Rules, 1965, citing violation of natural justice by submitting that the inquiry report was produced without completing necessary proceedings. The Court emphasized the necessity of finalizing inquiries before issuing notices. The inquiry was deemed incomplete, prompting the dismissal of the notice. The inquiry proceedings were to be resumed with duly afforded opportunities to the petitioner.

Result: The impugned show cause notice and inquiry report are quashed, and proceedings must follow CCS (CCA) Rules.

Table of Content
1. show cause notice quashed; inquiry must comply with legal standards. (Para 1 , 13)
2. inquiry procedures must complete before notices are issued. (Para 3 , 4 , 11)
3. parties must ensure cooperation during disciplinary procedures. (Para 9)

O R D E R

The petitioner appearing in person submits that he is not pressing this writ petition as against the third respondent for the present.

2. In view of the above submission, this writ petition is dismissed as not pressed as against the third respondent, while granting liberty to the petitioner to implead the third respondent in future litigation, if circumstance warrants.

3. This writ petition has been filed challenging the show cause notice vide Ref.No.GRI-DTBU/Estt.3/DRH&S/2025-2026/4547, dated 09.02.2026, issued by the first respondent, whereby the petitioner is required to show cause as to why a major penalty under Rule 11 r/w Rule 19 of the Central Civil Services (Classification, Control and Appeal) Rules, 1965 (in short, “CCS (CCA) Rules” should not be imposed upon him basing upon the inquiry report dated 06.01.2026.

4. The main ground of attack of the impugned show cause notice is on the ground that the inquiry proceedings were stayed on 09.12.2025 in the light of allegations of bias made by the petitioner against some of the members of the Inquiry Committee. But, without resuming the inquiry proceedings, the Inquiry Committee has submitted it's report on 06.01.2026 and it is based on the said report, the impugned show cause notice dated 09.02.2026 came to be issued. Thus, the petitioner, who appeared as a party- in-person, made out a grievance on the ground of violation of the principles of natural justice as the inquiry proceedings that were initiated against him were not taken to the logical end so as to enable the Inquiry Committee to submit it's report to the Disciplinary Authority.

5. Taking note of the same, this Court, by an order dated

17.03.2026, directed the respondents to produce the original records of the inquiry proceedings before this Court.

6. Accordingly, learned Standing Counsel appearing for the respondents 1 & 2 placed before this Court the original records of the inquiry proceedings.

7. A perusal of the same, in specific the inquiry proceedings dated

09.12.2025, discloses that the Inquiry Committee has chosen to stay the inquiry proceedings awaiting appropriate decision by the Disciplinary Authority. Admittedly, no inquiry proceedings have taken place after 09.12.2025. But, the Inquiry Committee appears to have submitted it's report on 06.01.2026, without properly concluding the inquiry proceedings, resulting in issuance of the impugned show cause notice.

8. In the light of the above, learned Standing Counsel appearing for the respondents 1 & 2 fairly submitted that because of the non-cooperative attitude of the petitioner, the Inquiry Committee is forced to conclude the disciplinary proceedings resulting in issuance of the impugned show cause notice.

9. This Court, after having perused the entire materials on record, also found that there are certain irrelevant questions that were put by the petitioner to some of the witnesses and it was when such irrelevant questions were objected to by the Inquiry Committee, the petitioner appears to have raised objections on various grounds alleging that the Inquiry Committee is not affording him reasonable opportunity. As some of the questions put by the petitioner are relating to the family particulars of some of the witnesses, this Court is also of the considered view that they are all nothing to do with the charges levelled against the petitioner and the petitioner ought not to have put such questions, which are all personal to the witnesses and their family particulars. It is always open for the Inquiry Committee to restrict the scope of cross-examination, when the questions put to the witnesses are beyond the scope of the inquiry and beyond the scope of the charges and the chief- examination. That power o

Click Here to Read the rest of this document
1
2
3
4
5
6
7
8
9
10
11
SupremeToday Portrait Ad
supreme today icon
logo-black

An indispensable Tool for Legal Professionals, Endorsed by Various High Court and Judicial Officers

Please visit our Training & Support
Center or Contact Us for assistance

qr

Scan Me!

India’s Legal research and Law Firm App, Download now!

For Daily Legal Updates, Join us on :

whatsapp-icon Back to top