Administrative authorities must pass reasoned orders personally as directed by appellate authorities without delegating to subordinates.

The petitioner was working as a ‘Guruji’ at the Education Guarantee Scheme (EGS) Centre in Bande Tola, Rewa. Based on a report by the Block Resource Coordinator (BRC) alleging that the school was non-operational and the petitioner was frequently absent, the Mission Director-Collector ordered the closure of the EGS Centre on 17.06.2011.

The petitioner appealed this decision before the Additional Commissioner, who, on 18.08.2011, set aside the closure and directed the Collector to conduct a detailed inquiry into six specific issues.

A five-member inquiry committee submitted its report on 25.05.2012. However, instead of the Collector passing a quasi-judicial order as directed, the District Project Coordinator (DPC) issued an order on 22.11.2013 dispensing with the petitioner’s services.

Subsequent appeals to the Collector and Additional Commissioner were dismissed as non-maintainable or rejected.

Whether the termination of the petitioner’s services and the closure of the EGS Centre were legally sustainable when the Collector failed to pass a final order in compliance with the specific directions issued by the appellate authority (Additional Commissioner)

The Court applied the principles of Administrative Law regarding the doctrine of functus officio and the mandatory nature of quasi-judicial directions issued by a superior appellate authority. It emphasized that when a superior authority (Additional Commissioner) remands a matter to a specific subordinate authority (Collector) with directions to conduct an inquiry and pass a reasoned order, that power cannot be delegated to or usurped by a lower-ranking official like the District Project Coordinator.

The court exercised its discretionary jurisdiction under Article 226 of the Constitution of India to ensure procedural fairness and compliance with the principles of natural justice.

The Court observed that the Additional Commissioner’s order dated 18.08.2011 explicitly mandated the Collector to investigate six distinct factual points, including pupil attendance and salary disbursement. The Court found that while an inquiry report was indeed prepared by a committee, the Collector failed to apply his mind to it or pass a formal order as directed.

Instead, the District Project Coordinator "stepped into the shoes of the Collector" and unauthorizedly passed the impugned order dated 22.11.2013. The Court reasoned that since the Collector, acting in a quasi-judicial capacity, had not yet passed the order required of him by the appellate authority, the subsequent termination and dismissal of appeals were procedurally flawed and lacked legal foundation.

The matter was remitted back to the Collector, Rewa, with a specific direction to pass a fresh order in strict compliance with the Additional Commissioner's directions dated 18.08.2011. The Collector was directed to provide the petitioner an opportunity for a hearing and to decide the matter within 90 days, without being influenced by previous quashed orders.