Supreme Court Sets Aside High Court's Remand Order in Service Dispute -- Matter Remanded Back to High Court for Comprehensive Consideration of All Issues

Nature of Litigation: Service dispute involving dismissal from employment and subsequent legal proceedings before the School Tribunal, High Court, and Supreme Court

Remedy Sought

The appellant sought setting aside of High Court orders that remanded the matter to the School Tribunal and sought proper consideration of all issues including breach of natural justice

Filing Reason

The appellant challenged the High Court's orders dated 05 September 2024 and 25 September 2024 which allowed the respondent's writ petition and dismissed the review petition respectively

Previous Decisions

The School Tribunal vide order dated 08 August 2019 set aside the appellant's dismissal and granted reinstatement with consequential benefits -- The High Court vide order dated 05 September 2024 allowed the respondent's writ petition and remanded the matter to the Tribunal -- The High Court vide order dated 25 September 2024 dismissed the appellant's review petition

Issues

Whether the High Court erred in remanding the matter to the School Tribunal based on consideration of only one point while ignoring other issues raised by the appellant Whether the disciplinary proceedings suffered from breach of principles of natural justice Whether the appellant would be entitled to back wages and retiral benefits given she had reached superannuation age

Submissions/Arguments

The appellant contended that disciplinary proceedings were conducted in gross breach of natural justice as she was not allowed to cross-examine all prosecution witnesses -- The inquiry officer abruptly closed proceedings without granting opportunity to complete cross-examination The appellant argued that the Tribunal had found the charges not proved and the High Court should have considered this aspect The appellant submitted that the High Court focused only on whether the Secretary was authorized to initiate proceedings while ignoring other crucial issues

Ratio Decidendi

When several issues arise for consideration in a case, a court should ideally record answers to each issue with reasons rather than focusing on just one decisive point -- This approach ensures comprehensive consideration, provides clarity, assures finality, respects litigants' rights, and benefits appellate courts -- A court's failure to deal with all issues while deciding only one single point constitutes a fundamental flaw vitiating its order

Judgment Excerpts

"Law is pretty well-settled that when several issues arise for being answered by a Court in the facts of a given case, ideally, disposal thereof ought to be preceded by recording the Court's answers to each of such issues with reasons rather than the decision of the Court focusing on just one decisive point" -- Para 9 "The High Court, thus, appears to have faltered in deciding only one single point while not dealing with the others, which is a fundamental flaw vitiating its order dated 5th September, 2024" -- Para 10 "Since the appellant has reached the age of superannuation and there is, thus, no question of her reinstatement in service, inter alia, the primary questions that would necessarily arise for decision before the High Court are whether: (i) the Tribunal was justified in interfering with the disciplinary action taken by the first respondent against the appellant and (ii) the appellant would be entitled to back wages as well as retiral benefits, should the first question be decided against the first respondent" -- Para 11

Procedural History

The appellant was dismissed from service by the first respondent -- The School Tribunal, Nagpur vide order dated 08 August 2019 set aside the dismissal and granted reinstatement with consequential benefits -- The first respondent filed Writ Petition No.5899 of 2019 before the High Court -- The High Court vide order dated 05 September 2024 allowed the writ petition and remanded the matter to the Tribunal -- The appellant filed Review Petition MRA No.838/2024 which was dismissed by the High Court on 25 September 2024 -- The appellant filed Special Leave Petitions before the Supreme Court which were converted into Civil Appeals