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Violation of principles of natural justice in departmental inquiry proceedings. Analysis: The appeal before the Supreme Court centered around the question of whether the departmental inquiry proceedings, specifically the constitution of the Inquiry Committee and the subsequent dismissal order, were tainted by a violation of the principles of natural justice. The respondent, a former treasure guard in the Eastern Railway, faced charges of misappropriation of government funds. The Inquiry Committee, initially comprising three members, continued its proceedings after one member was replaced. The High Court held that the change in committee members affected the fairness of the inquiry, citing the necessity for the decision-makers to hear all evidence directly. However, the Supreme Court disagreed with this view. The Supreme Court examined the relevant rules under the Indian Railway Establishment Code governing disciplinary inquiries for railway servants. The rules outlined a detailed procedure, including the framing of charges, submission of written statements, examination of evidence, and preparation of a report by the Inquiry Committee. Crucially, the Disciplinary Authority, not the Inquiry Committee, had the final decision-making power based on the inquiry record. The Court emphasized that the personal impressions of individual committee members did not influence the collective findings or the subsequent decision of the Disciplinary Authority. Furthermore, the Court distinguished the present case from precedents where personal hearings were crucial for decision-makers. It highlighted that in this context, the Inquiry Committee's role was to compile evidence and findings, with the Disciplinary Authority independently assessing the record to determine penalties. Drawing parallels to trial court procedures, the Court noted that multiple judges or magistrates often recorded evidence, and appellate courts relied on case records rather than witness demeanor. Therefore, the Court concluded that the High Court erred in quashing the dismissal order based on alleged violations of natural justice principles, ultimately allowing the appeal and setting aside the High Court's decision. In summary, the Supreme Court's judgment clarified the distinct roles of the Inquiry Committee and the Disciplinary Authority in disciplinary proceedings, emphasizing the primacy of the inquiry record in decision-making. The Court rejected the notion that a change in committee members during the inquiry process compromised natural justice principles, citing established legal procedures and precedents from trial court settings.
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