High Court Upholds Judicial Scrutiny of SGPC Employment Disputes

In a significant judgment delivered on December 17, 2025, the High Court of Punjab and Haryana at Chandigarh has affirmed that writ petitions under Article 226 of the Constitution are maintainable against the Shiromani Gurudwara Parbhandhak Committee (SGPC). While rejecting a batch of petitions challenging disciplinary actions, Justice Harpreet Singh Brar clarified the legal standing of the SGPC’s service regulations, reinforcing the judiciary's power to intervene when public law elements are at play.

The Conflict: Missing Saroops and Withheld Dues

The legal battle originated from a series of writ petitions filed by former employees of the SGPC, including the lead petitioner, Kanwaljit Singh. Upon his superannuation in May 2020, Mr. Singh’s retiral benefits—including leave encashment, gratuity, and provident fund—were withheld.

The SGPC justified this action by citing a departmental inquiry into the mismanagement and loss of 328 Holy Saroops of Sri Guru Granth Sahib from the publication department. The petitioner contended that the withholding of funds without a finalized disciplinary order or proper show cause notice violated his rights and imposed severe financial hardship.

Arguments: Statutory Duty vs. Private Contract

The SGPC challenged the maintainability of the petitions, arguing that its relationship with its employees is essentially private. Citing Supreme Court precedents such as St. Mary's Education Society v. Rajendra Prasad Bhargava , the respondent argued that the SGPC’s Service Rules are merely internal procedural guidelines, not statutory imperatives, and thus the court should not intervene under Article 226.

Conversely, the petitioners asserted that the SGPC is a statutory body, and its Service Rules were previously recognized as having the "force of law" by the Supreme Court in cases like Mewa Singh v. SGPC . They maintained that because these rules were framed under the authority conferred by the Sikh Gurdwaras Act, 1925 , the court possessed the inherent jurisdiction to examine any breach of service conditions.

Judicial Analysis: Balancing Statutory Power and Natural Justice

Justice Harpreet Singh Brar meticulously examined the legislative framework of the Sikh Gurdwaras Act, 1925 , specifically Section 69 . The Court concluded that this provision bestows the Executive Committee with explicit statutory power to determine service conditions, thereby making the SGPC amenable to writ jurisdiction.

However, on the merits of the disciplinary action, the Court found the petitioners' claims lacking. Analyzing the principles of natural justice and the test of prejudice, the bench noted that the inquiry against the employees was conducted fairly. The employees had been granted opportunities to participate and lead evidence, which they failed to utilize.

Key Observations

• On Maintainability: "A mere reading of various provisions of the Act and Rules set out above unmistakably show that SGPC is a creation of the statute and Service Rules framed by it in exercise of its statutory power have force of law."
• On Judicial Intervention: "Any violation of the provision of the Act and the Rules will certainly make SGPC amenable to writ jurisdiction of the High Court under Article 226 of the Constitution."
• On Procedural Fairness: "The ultimate test is always the same viz., test of prejudice or the test of fair hearing... whether in the totality of the circumstances, the delinquent officer/employee did or did not have a fair hearing."

The Verdict: Final Decision

The High Court ultimately dismissed the batch of writ petitions. While the Court affirmed that the SGPC is subject to judicial review—a win for employees seeking legal recourse against arbitrary administrative acts—it declined to intervene in this specific instance, finding that the disciplinary proceedings had satisfied the requirements of natural justice and that the punishment was commensurate with the grave misconduct uncovered during the investigation.

This judgment serves as a precedent for future disputes, clarifying that while SGPC is subject to the constitutional scrutiny of the High Courts, its employees are also bound by the rigorous procedural standards established by the committee’s statutory regulations.