The Supreme Court set aside judgments of the Uttarakhand High Court, which had dismissed a writ petition filed by the appellant, former Registrar of G.B. Pant Institute of Engineering and Technology. The appellant’s services were terminated without a disciplinary inquiry, and the Court found this to be a violation of natural justice. The appellant was reinstated with all consequential benefits, and the Institute was granted the liberty to conduct proper disciplinary proceedings if necessary.

1. Background:

   • The appellant was appointed as Registrar of G.B. Pant Institute of Engineering and Technology (Institute) on 2nd December 2019, subject to a probation period of one year.
   • On 19th May 2022, the appellant's services were terminated by the Institute without any prior disciplinary inquiry, leading to the appellant filing a writ petition with the Uttarakhand High Court.

2. High Court's Judgments:

   • The Uttarakhand High Court, on 4th August 2022, dismissed the writ petition filed by the appellant, citing non-disclosure of the minutes of the 26th Board of Governors meeting dated 16th June 2018.
   • A subsequent review petition filed by the appellant was also dismissed by the High Court on 21st February 2023.

3. Supreme Court Appeal:

   • The appellant challenged the High Court's decisions before the Supreme Court, arguing that his failure to place the minutes on record was not intentional and that the minutes supported his case.
   • The Supreme Court found that the appellant’s selection was indeed approved by the Board of Governors during their 26th meeting, contrary to what was claimed in the termination letter.

4. Key Legal Arguments:

   • For the Appellant: The termination was procedurally improper as no inquiry or show cause notice was issued, violating natural justice. The appellant had completed the probation period without any objections.
   • For the Respondents: The appellant’s appointment was argued to be illegal due to non-fulfillment of qualifications. Furthermore, the appellant had concealed material facts in the original writ petition.

5. Supreme Court Decision:

   • The Supreme Court held that terminating the appellant’s services without a proper inquiry was unjustified. It quashed the High Court's judgments and reinstated the appellant with all consequential benefits.

Acts and Sections Discussed:

• Constitution of India, Article 226: The appellant filed a writ petition under this provision, which grants the High Courts the authority to issue directions, orders, or writs for enforcement of fundamental rights or for any other purpose.
• Principles of Natural Justice: The termination was found to be in violation of the principles of natural justice as the appellant was not given an opportunity to present his case or defend himself in a proper inquiry.

Ratio:

• The Supreme Court emphasized that any termination of services must follow due process, including conducting an appropriate disciplinary inquiry if needed. A dismissal solely on procedural grounds, such as non-disclosure of a document, is hyper-technical when the document supports the appellant’s case.

Subjects: Employment Law, Termination of Service, Principles of Natural Justice Termination without Inquiry, Reinstatement, Registrar Termination, Probationary Period, Disciplinary Proceedings