Service Law — Disciplinary Proceedings — Judicial Review — Remand by High Court — Impermissibility of Deciding on Single Point (Paras 8–10) Where several substantial issues arise in a writ petition challenging disciplinary action, the High Court must adjudicate all material issues with reasons. Remanding a matter solely on one procedural aspect (authorization to initiate proceedings) without examining: Alleged breach of principles of natural justice, Legality of inquiry proceedings, Correctness of Tribunal’s findings, constitutes a fundamental flaw vitiating the order.

Service Law — Disciplinary Proceedings — Judicial Review — Remand by High Court — Impermissibility of Deciding on Single Point

(Paras 8–10)

Where several substantial issues arise in a writ petition challenging disciplinary action, the High Court must adjudicate all material issues with reasons.

Remanding a matter solely on one procedural aspect (authorization to initiate proceedings) without examining:

• Alleged breach of principles of natural justice,

• Legality of inquiry proceedings,

• Correctness of Tribunal’s findings,

constitutes a fundamental flaw vitiating the order.

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Judicial Discipline — Duty to Record Findings on All Issues

(Para 9)

It is settled law that when multiple issues arise, the Court must:

• Record findings on each issue,

• Assign reasons,

• Avoid selective adjudication on a single decisive point.

Such an approach ensures clarity, finality, and assists appellate review.

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Disciplinary Proceedings — Natural Justice — Denial of Cross-Examination

(Paras 5, 8)

Where employee alleges:

• Closure of inquiry mid cross-examination,

• Denial of opportunity to cross-examine prosecution witnesses,

such allegations go to the root of fairness and must be examined by the writ court before remand.

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Superannuation — Relief — Reinstatement Infructuous

(Para 11)

Upon employee reaching age of superannuation:

• Reinstatement becomes academic,

• Surviving issues are:

  • Justification of Tribunal’s interference,

  • Entitlement to back wages,

  • Entitlement to retiral benefits.

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FACTUAL MATRIX

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Tribunal Stage

The School Tribunal, Nagpur (8 August 2019):

• Set aside dismissal order,

• Granted reinstatement with consequential benefits.

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High Court Stage

Bombay High Court (Nagpur Bench)

• Allowed writ petition filed by management (5 September 2024).

• Quashed Tribunal’s order.

• Remanded matter to Tribunal.

• Considered only one issue:

  • Whether Secretary was authorized via resolution to initiate disciplinary proceedings.

No consideration was given to:

• Alleged breach of natural justice,

• Cross-examination issues,

• Merits of Tribunal’s findings.

Review petition rejected on 25 September 2024.

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ISSUES BEFORE THE SUPREME COURT

1. Whether High Court erred in remanding matter based on a solitary procedural issue?

2. Whether High Court was required to adjudicate all substantial issues?

3. What relief survives post-superannuation?

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ANALYSIS

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I. Selective Adjudication — A Jurisdictional Error

The Supreme Court held that the High Court:

• Focused exclusively on authorization of Secretary,

• Ignored substantive grounds challenging disciplinary inquiry,

• Failed to evaluate whether principles of natural justice were violated.

Such selective adjudication renders the decision legally unsustainable.

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II. Denial of Cross-Examination — Root Violation

Appellant contended:

• Cross-examination of main management witness was ongoing on 31 July 2017.

• Inquiry officer abruptly closed proceedings on 1 August 2017.

• Opportunity to cross-examine remaining witnesses denied.

These allegations:

• Strike at the core of fair hearing,

• Engage audi alteram partem,

• Required judicial examination.

High Court omitted consideration of these material aspects.

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III. Doctrine of Comprehensive Issue Determination

Para 9 articulates an important judicial principle:

Courts must answer each issue arising in the case with reasons rather than focusing on a single decisive point.

Rationale:

• Protects litigant’s right to reasoned justice,

• Prevents piecemeal adjudication,

• Assists appellate scrutiny,

• Promotes judicial discipline.

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IV. Superannuation — Shift in Relief

Since appellant attained superannuation:

Reinstatement no longer survives.

High Court must now determine:

1. Was Tribunal justified in interfering with disciplinary action?

2. Is appellant entitled to back wages and retiral benefits?

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RATIO DECIDENDI

1. A High Court commits a fundamental adjudicatory error when it decides a writ petition on a single procedural issue while ignoring other substantial issues.

2. Allegations of breach of natural justice in disciplinary proceedings must be examined before remanding.

3. Reasoned findings on all material issues are mandatory for judicial legitimacy and appellate efficacy.

4. Upon superannuation, reinstatement becomes infructuous; entitlement shifts to monetary and retiral consequences.