Administrative orders entailing civil consequences must adhere to the principles of natural justice.

The petitioners, originally Class-IV employees, were promoted to the post of Assistant Grade-III via an order dated 13.09.2024 following a Departmental Promotion Committee (DPC) recommendation

On 24.09.2024, the State constituted an enquiry committee following complaints of discrepancies in the seniority list (specifically, the omission of 25 names in the final list compared to the provisional list)

On 04.10.2024, the Respondent No. 3 (CMHO, Mungeli) issued an impugned order cancelling the petitioners' promotions without providing a prior notice or an opportunity for a hearing

1. Whether the cancellation of a promotion order involving civil consequences without providing an opportunity of hearing violates the principles of natural justice.

2. Whether an administrative order that results in prejudice to a person must adhere to the rule of audi alteram partem even in the absence of specific statutory provisions.

The Court applied the fundamental principle of Audi Alteram Partem (duty to act judicially), asserting that where an administrative power is exercised to the prejudice of a person, the duty to act judicially is implicit

It relied on the trite law that any administrative action involving "civil consequences" must be consistent with the rules of natural justice, regardless of whether the body is quasi-judicial or purely administrative

The Court observed that the petitioners had already joined their promoted posts and were working when the cancellation order was issued

The Court found that while the State alleged discrepancies in the seniority list—citing that the final list contained only 71 names instead of 96—this did not exempt the State from procedural fairness

The Court reasoned that since the cancellation order deprived the petitioners of their promoted status, it carried significant civil consequences

The State failed to produce any evidence that a show-cause notice was issued or that the petitioners were allowed to explain the alleged discrepancy before their promotions were quashed

Consequently, the Court determined that the unilateral cancellation was a "clear violation of principles of natural justice" and could not be sustained in law

The High Court allowed both writ petitions and quashed the impugned order dated 04.10.2024 passed by the Chief Medical and Health Officer

The Court reserved liberty for the State to take fresh steps in accordance with the law to examine the validity of the promotions, provided due process is followed