प्रबंध निदेशक, ECIL बनाम बी. कारुणाकर
| Citation | (1993) 4 SCC 727 |
| Court | Supreme Court of India (Constitution Bench) |
| Date | 11 November 1993 |
| Year | 1993 |
| Bench | M.N. Venkatachaliah CJ, J.S. Verma, A.M. Ahmadi, G.N. Ray, A.S. Anand JJ. |
| Acts/Articles | Article 14, Article 311 |
| Category | Constitutional Law, Service & Employment Law |
Key Principle Established
Non-supply of inquiry report before imposing punishment in departmental proceedings violates principles of natural justice. The delinquent employee has a right to receive the inquiry report before the disciplinary authority passes final order.
Employees of Electronic Corporation of India Ltd. were dismissed based on inquiry reports that were never supplied to them before the final order of punishment.
The Constitution Bench held:
This Constitution Bench decision is the definitive authority on supply of inquiry report in departmental proceedings. It has changed the practice across all government departments and is cited in every disciplinary proceeding challenge.
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Read AnalysisThis judgment summary is for educational and research purposes. While care has been taken to accurately represent the ratio and findings, for authoritative reference always consult the original judgment text from official sources (SCC Online, AIR, Manupatra, or court websites).
22+ years of practice before Punjab & Haryana High Court and Supreme Court of India.