A Show-Cause Notice Allowing Less Than 24 Hours to Respond Violates Natural Justice.

The petitioner challenged an NCISM order dated 8 September 2026 imposing a penalty of ₹1 crore and a further order dated 17 September 2026 denying permission to admit students for the 2026–27 academic session.

The show-cause notice was issued on 9 April 2026 at 2:46 p.m., with a response required by 2:00 p.m. the following day; the petitioner replied on 10 April and attended a hearing on 13 April.

The respondents relied on a further notice dated 25 June 2026 and hearings of faculty members on three dates; the Court found that the June notice sought additional documents and was not a further show-cause notice.

The challenged orders were made more than five months after the original notice.

1. Whether the show-cause process—allowing less than 24 hours to respond and stating that no post-hearing submission would be permitted—violated the principles of natural justice.

2. Whether the availability of a statutory appeal under Section 24(3) of the National Commission for Indian System of Medicine Act, 2020, precluded the Court from exercising its jurisdiction under Article 226.

Article 226 jurisdiction is not ousted merely because an alternative statutory remedy is available; exhaustion of that remedy is a self-imposed restraint, subject to recognised exceptions, including a breach of natural justice.

The Court relied on Rikhab Chand Jain v. Union of India, 2025 SCC OnLine SC 2510, which reaffirmed that an alternative remedy does not constitute an absolute bar to writ jurisdiction.

Section 24(3) of the National Commission for Indian System of Medicine Act, 2020 provides a statutory First Appeal, but its availability did not bar writ review in this case.

State action must comply with natural justice meaningfully and substantially, rather than as a paper formality.

The Court held that less than 24 hours was inadequate to answer the allegations, particularly when the notice also barred post-hearing submissions.

The respondents’ later notice did not cure the defect because it sought documents rather than responses to the allegations; nor did hearings of individual faculty members remedy the denial of a proper opportunity to the college itself.

The Court further noted that the orders were not issued until more than five months after the show-cause notice, undermining the need for the unusually short response period.

Because the challenge raised a natural-justice violation, the statutory appeal did not prevent the Court from exercising its writ jurisdiction.

It directed the petitioner to respond to the 9 April 2026 show-cause notice within one week of uploading of the order and the respondents to adjudicate the matter in accordance with law within the following week.