Tuesday 28 June 2022

Whether principles of natural justice violated if an enquiry report is not given to a delinquent employee?

 As stated above, Annexure – A8 enquiry report and PR

minutes were given to the applicant only along with Annexure – A7 show cause notice after the Government accepted the findings in the enquiry report and provisionally decided to impose a penalty. It is pertinent to note that the enquiry officer and the disciplinary authority in the instant case were not one and the same. This is in violation of the principles of natural justice and the same cannot be condoned at all, as held in B. Karunakar's Case (supra)

“The findings or recommended punishment by the

enquiry officer are likely to affect the mind of the

disciplinary authority in his concluding the guilt or

penalty to be imposed. The delinquent is, therefore,

entitled to meet the reasoning, controvert the

conclusions reached by the enquiry officer or is entitled

to explain the effect of the evidence recorded. Unless

the copy of the report is supplied to him, he would be in

dark to know the findings, the reasons in support

thereof or nature of the recommendation on penalty. He

would point out all the factual or legal errors committed

by the enquiry officer. He may also persuade the

disciplinary authority that the finding is based on no

evidence or the relevant material evidence was not

considered or overlooked by the enquiry officer in

coming to the conclusions, with a view to persuade the

disciplinary authority to disagree with the enquiry

officer and to consider his innocence of the charge, or

even that the guilt as to the misconduct has not been

established on the evidence on records or disabuse the

initial impression formed in the minds of the

disciplinary authority on consideration of the enquiry

report. Even if the disciplinary authority comes to the

conclusion that charge or charges is/are proved, the case

may not warrant imposition of any, penalty. He may

plead mitigating or extenuating circumstances to impose

no punishment or a lesser punishment. For this purpose

the delinquent needs reasonable opportunity or fair play

in action. The supply of the copy of the report is neither

an empty formality, nor a ritual, but aims to digress the

direction of the disciplinary authority from his

derivative conclusions from the report to the palliative

path of fair consideration. The denial of the supply of

the copy, therefore, causes to the delinquent a grave

prejudice and avoidable injustice which cannot be cured

or mitigated in appeal or at a challenge under Art. 226

of the Constitution or S.19 of the Tribunal Act or other

relevant provisions. Ex post facto opportunity does not

efface the past impression formed by the disciplinary

authority against the delinquent, however, professedly

to be fair to the delinquent. The lurking suspicion

always lingers in the mind of the delinquent that the

disciplinary authority was not objective and he was

treated unfairly. To alleviate such an impression and to

prevent injustice or miscarriage of justice at the

threshold, the disciplinary authority should supply the

copy of the report, consider objectively the records, the

evidence, the report and the explanation offered by the

delinquent and make up his mind on proof of the charge

or the nature of the penalty. The supply of the copy of

the report is thus, a sine qua non for a valid, fair, just

and proper procedure to defend the delinquent himself

effectively and efficaciously. The denial thereof is

offending not only Art.311(2) but also violates Arts. 14

and 21 of the Constitution. {Para 7}

8. The argument on the side of the Government before the

Tribunal that there is no specific rule in the Kerala Police

Departmental Inquiries, Punishment and Appeal Rules to give enquiry report at the stage of drawing up of the same to the delinquent cannot be accepted at all. The right to receive the report is considered as the essential part of reasonable opportunity to be extended to the person affected by the report and a refusal to furnish the report amounts to denial of the right to defend himself and to prove his innocence in the disciplinary proceedings. Even if such right is not explicitly stated in the regulations or statute, that right being a fundamental and essential part of the natural justice, must be read into every regulation or rules. There is nothing in the rules aforesaid

which excludes the operation of the principle of natural justice

entitling the delinquent to be served with a copy of the enquiry

report before accepting the report or proposing a punishment. It is trite that the principles of natural justice must be read into the

unoccupied interstices of the statute/rules or regulations unless there is a clear mandate to the contrary.

IN THE HIGH COURT OF KERALA AT ERNAKULAM

OP (KAT) No. 130 of 2022

JAYACHANDRAN V  Vs STATE OF KERALA

PRESENT

 MR. JUSTICE A.K.JAYASANKARAN NAMBIAR

&

MR.JUSTICE MOHAMMED NIAS C.P.

Author: Mohammed Nias.C.P., J.

Dated: 16th day of June, 2022

The petitioner is the applicant in O.A.(EKM) 1842 of 2020

questioning the dismissal of his Original Application filed challenging

Annexure-A8 enquiry report/PR Minutes, Annexures -A10 and A12 to

the extent the applicant was given the penalty of barring of three

increments with cumulative effect in the departmental enquiry initiated

as per Annexure – A1 memo of charges. Departmental enquiry was

initiated against the petitioner on the allegation that he while

working as Inspector of Police, Museum Police Station,

Thiruvananthapuram City, manhandled one K.G. Suresh Babu at 10.

30 p.m on 3-1-2014 and also registered a false case against him. The

petitioner denied the charges stating that the car belonging to K.G.

Suresh Babu was parked very near to Raj Bhavan on 3-1-2014

when the Hon'ble Prime Minister of India was camping in the Raj

Bhavan. Since Sri. Suresh Babu did not bother to answer on being

asked as to why the car is being parked there, the petitioner had to

arrest and take him to the police station. It is alleged that the

Enquiry Officer was biased and had submitted Annexure-A10 report

which was accepted by the disciplinary authority who issued Annexure-

A7 show cause notice proposing the penalty of reversion of the

petitioner to a lower category of Sub Inspector for a period of five

years. By Annexure A-10, disciplinary proceedings were finalised by

awarding him the penalty of barring of three increments with

cumulative effect. Petitioner filed Annexure-A11 statutory review

petition before the Government which was rejected by Annexure-A12

order.

2. The Tribunal dismissed the Original Application by

rejecting the contention of the petitioner that copy of the enquiry

report was not furnished to him soon after it was drawn up and the

same was given only after a provisional decision was taken to impose a

penalty of reduction of rank for a period of five years, by relying on

Rule 17 (i) (b) of the Kerala Police Departmental Inquiries,

Punishment and Appeal Rules, (KPDIP) & A Rules.

3. The contention of the Government that only after the

disciplinary authority takes a decision, the copy of the report need to

be given to the delinquent employee, together with the findings of

the disciplinary authority on the enquiry report, was accepted and

accordingly holding that there were no grounds to interfere with the

orders impugned, the Original Application was dismissed.

4. Before us, it is the specific contention of the learned

counsel for the petitioner that there was no legally reliable evidence

against the petitioner and that the disciplinary authority accepted the

enquiry report and decided to punish the petitioner before giving a

copy of the enquiry report to the delinquent or obtaining his remarks

which deprived the petitioner of his right to point out the vitiating

factors of the enquiry report and also for avoiding punishment on the

basis of such a report. The enquiry officer and the disciplinary

authority not being one and the same, a copy of the report ought to

have been given to the delinquent before the disciplinary authority

decided on the further course of action to be taken on the report. The

learned counsel also argues that Annexure-A13, which was the

Government letter dated 21-1-2016 by which the request of Sri. K.G.

Suresh Babu for sanction to prosecute the petitioner was rejected was

not considered at all.

5. This Court by order dated 24-5-2022 directed the

Government Pleader to get instructions on the primary contention of

the petitioner regarding the failure to furnish enquiry report which was

against the the dictum laid down by the Constitution Bench of the

Apex Court in Managing Director, ECIL v. B. Karunakar [(1993) 4 SCC

727] and as to whether the matter could be remitted to be done

afresh from that stage and in adherence to the dictum laid down in B.

Karunakar's Case (supra).

6. We notice that on going through Annexure-A7 show

cause notice dated 28-09-2016, that a decision was taken to revert

the petitioner as Sub Inspector for a period of five years provisionally

and an explanation was sought as if the enquiry report is being

accepted in full and the concurring with the findings of the guilt

rendered in the enquiry report/punishment, and the opportunity was

given only to show cause as to why provisional decision regarding

the proposed imposition of penalty of reversion to a lower post shall

not be finally passed. It is crystal clear that the enquiry report was

not served on the appellant before or an opportunity to plead why

the findings in the enquiry report should not be accepted by the

disciplinary authority or on the quantum of punishment was offered to

the petitioner. This action flies in the face of the dictum laid down by

the Constitution Bench in B. Karunakar's Case (supra).

7. As stated above, Annexure – A8 enquiry report and PR

minutes were given to the applicant only along with Annexure – A7

show cause notice after the Government accepted the findings in the

enquiry report and provisionally decided to impose a penalty. It is

pertinent to note that the enquiry officer and the disciplinary authority

in the instant case were not one and the same. This is in violation of the principles of natural justice and the same cannot be condoned at all, as held in B. Karunakar's Case (supra)

“The findings or recommended punishment by the

enquiry officer are likely to affect the mind of the

disciplinary authority in his concluding the guilt or

penalty to be imposed. The delinquent is, therefore,

entitled to meet the reasoning, controvert the

conclusions reached by the enquiry officer or is entitled

to explain the effect of the evidence recorded. Unless

the copy of the report is supplied to him, he would be in

dark to know the findings, the reasons in support

thereof or nature of the recommendation on penalty. He

would point out all the factual or legal errors committed

by the enquiry officer. He may also persuade the

disciplinary authority that the finding is based on no

evidence or the relevant material evidence was not

considered or overlooked by the enquiry officer in

coming to the conclusions, with a view to persuade the

disciplinary authority to disagree with the enquiry

officer and to consider his innocence of the charge, or

even that the guilt as to the misconduct has not been

established on the evidence on records or disabuse the

initial impression formed in the minds of the

disciplinary authority on consideration of the enquiry

report. Even if the disciplinary authority comes to the

conclusion that charge or charges is/are proved, the case

may not warrant imposition of any, penalty. He may

plead mitigating or extenuating circumstances to impose

no punishment or a lesser punishment. For this purpose

the delinquent needs reasonable opportunity or fair play

in action. The supply of the copy of the report is neither

an empty formality, nor a ritual, but aims to digress the

direction of the disciplinary authority from his

derivative conclusions from the report to the palliative

path of fair consideration. The denial of the supply of

the copy, therefore, causes to the delinquent a grave

prejudice and avoidable injustice which cannot be cured

or mitigated in appeal or at a challenge under Art. 226

of the Constitution or S.19 of the Tribunal Act or other

relevant provisions. Ex post facto opportunity does not

efface the past impression formed by the disciplinary

authority against the delinquent, however, professedly

to be fair to the delinquent. The lurking suspicion

always lingers in the mind of the delinquent that the

disciplinary authority was not objective and he was

treated unfairly. To alleviate such an impression and to

prevent injustice or miscarriage of justice at the

threshold, the disciplinary authority should supply the

copy of the report, consider objectively the records, the

evidence, the report and the explanation offered by the

delinquent and make up his mind on proof of the charge

or the nature of the penalty. The supply of the copy of

the report is thus, a sine qua non for a valid, fair, just

and proper procedure to defend the delinquent himself

effectively and efficaciously. The denial thereof is

offending not only Art.311(2) but also violates Arts. 14

and 21 of the Constitution.

8. The argument on the side of the Government before the

Tribunal that there is no specific rule in the Kerala Police

Departmental Inquiries, Punishment and Appeal Rules to give enquiry

report at the stage of drawing up of the same to the delinquent cannot

be accepted at all. The right to receive the report is considered as the

essential part of reasonable opportunity to be extended to the

person affected by the report and a refusal to furnish the report

amounts to denial of the right to defend himself and to prove his

innocence in the disciplinary proceedings. Even if such right is not

explicitly stated in the regulations or statute, that right being a

fundamental and essential part of the natural justice, must be read

into every regulation or rules. There is nothing in the rules aforesaid

which excludes the operation of the principle of natural justice

entitling the delinquent to be served with a copy of the enquiry

report before accepting the report or proposing a punishment. It is

trite that the principles of natural justice must be read into the

unoccupied interstices of the statute/rules or regulations unless there

is a clear mandate to the contrary.

9. Under these circumstances, we have no option but to set

aside the order dated 9th March 2022 of the Kerala Administrative

Tribunal in OA 1842 of 2020 and to allow this Original Petition.


10. We direct that the enquiry proceedings will have to start

afresh from the stage of drawing up of the enquiry report and by giving

a copy of the said report to the delinquent to offer his explanation on

the findings in the enquiry report and as to why the enquiry report

cannot be accepted. The delinquent should also be given an

opportunity to show cause against the proposed punishment. The

disciplinary authority may decide as to the necessity of separate

notices for the above or a composite notice.

The proceedings will commence as aforesaid and will be

proceeded on the basis of the rules keeping in mind the dictum of law

laid down in B. Karunakar's Case (supra). The proceedings as directed

above will be completed within a period of six months from the date of

receipt of a copy of this judgment.


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