Acceptance of resignation severs master-servant relationship, precluding continuation of disciplinary proceedings and holding of terminal benefits.

The petitioner was appointed as an Associate Professor at IIM Kashipur on 14.06.2012 and promoted to Professor on 31.05.2014

During his tenure, disciplinary proceedings were initiated against him via memorandums dated 28.01.2023 and 19.09.2023

The petitioner subsequently tendered his resignation on 31.10.2024, which was accepted by the Competent Authority on 30.01.2025

The petitioner filed this writ petition seeking to quash the disciplinary proceedings and challenging the validity of certain service regulations of IIM Kashipur

During the hearing, the respondent-Institute contended that since the resignation was accepted, the master-servant relationship had severed, rendering the disciplinary proceedings and the writ petition infructuous

1. Whether disciplinary proceedings can continue against an employee after the acceptance of their resignation and the subsequent severance of the master-servant relationship.

2. Whether a pending (and subsequently aborted) disciplinary inquiry can be used to prejudice the petitioner's future employment prospects or withhold pending dues.

Master-Servant Relationship: basic principle of service jurisprudence dictates that once a resignation is accepted without any reservation to continue proceedings under specific rules (such as pension rules), the employer loses disciplinary jurisdiction over the former employee

The court also exercised its discretionary power under Article 226 of the Constitution of India to ensure that an aborted inquiry does not result in a "stigma" that hinders the Right to Livelihood and future employment of the citizen

The court's reasoning was predicated on the formal admission made by IIM Kashipur’s counsel. The respondent conceded that the acceptance of the petitioner's resignation resulted in the severance of the master-servant relationship, which legally precluded the Institute from proceeding further with any departmental inquiry

The court linked this legal severance to the resolution of the petitioner's grievances; since the Institute "cannot now proceed departmentally," the primary relief sought regarding the quashing of proceedings was effectively rendered moot by operation of law

Consequently, the court determined that the pending charge-sheet, having been "aborted" by the employer's own action of accepting the resignation, lost its legal efficacy and could not be used as a ground to withhold dues or act as a bar for future opportunities

The Court directed the Competent Authority of IIM Kashipur to process and release all pending dues of the petitioner within three months. It further held that since the enquiry was aborted due to the acceptance of resignation, the charge-sheet issued to the petitioner shall not impede his ability to seek or gain employment elsewhere