A general fact-finding enquiry remains valid despite subsequently implicating an employee.

The petitioner challenged orders dated 16.02.2026 and 11.03.2026, by which respondent No. 4 constituted a three-member Preliminary Enquiry Committee concerning registration-related records and the Committee submitted its report. She also challenged the charge-sheet dated 12.05.2026 and consequential departmental proceedings

The petitioner contended that respondent Nos. 4 and 5 were neither her appointing nor disciplinary authorities and therefore lacked jurisdiction to constitute the Committee. She further alleged that the Committee exceeded its limited mandate by recommending disciplinary action without hearing her

The State maintained that the enquiry was a general internal fact-finding exercise and was not directed against the petitioner individually. The petitioner’s name allegedly surfaced during examination of the records, revealing prima facie irregularities, following which departmental action was contemplated under the applicable service rules

The Court dismissed the writ petition at the motion stage

Whether the Preliminary Enquiry Committee was without jurisdiction because it was constituted by an authority that was not the petitioner’s appointing or disciplinary authority?

Whether the Committee’s report and recommendation for departmental action were invalid because the petitioner was not given an opportunity of hearing during the preliminary fact-finding enquiry?

Whether the charge-sheet and consequential departmental proceedings were liable to be quashed merely because they were founded, in part, on the preliminary enquiry report?

A preliminary enquiry is ordinarily a fact-finding exercise and does not amount to a final determination of misconduct or guilt; the employee is entitled to defend herself in the subsequent departmental proceedings conducted under the applicable service rules

The Court considered the principle relied upon from State of Odisha & Another v. Satish Kumar Ishwardas Gajbhiye & Others, (2021) 17 SCC 90, namely that an authority may exercise only those powers conferred upon it by law and cannot assume jurisdiction by implication

However, the Court distinguished that precedent where the enquiry is a general internal enquiry and is not specifically directed against the employee

The Court found from the record that the Committee had been constituted to conduct a general enquiry into registration-related records, rather than a disciplinary enquiry specifically against the petitioner

The fact that the petitioner’s name appeared during that enquiry did not establish that the Committee had been constituted against her with a predetermined intention to initiate disciplinary proceedings

Since the preliminary exercise merely collected and noticed material and did not finally determine guilt, the absence of a prior opportunity of hearing at that stage did not invalidate the subsequent disciplinary process; the petitioner would have a full opportunity to defend herself in the departmental proceedings

Accordingly, the jurisdictional challenge and reliance on Satish Kumar Ishwardas Gajbhiye were rejected as inapplicable on the facts

It found no ground to interfere with the orders dated 16.02.2026 and 11.03.2026, the charge-sheet dated 12.05.2026, or the consequential departmental proceedings. The writ petition was dismissed as devoid of merit at the motion stage