Anonymous complaints containing verifiable allegations warrant preliminary enquiry and subsequent departmental action despite restrictive executive guidelines.

The petitioner, a Joint Commissioner of Labour in Dindigul, challenged a preliminary enquiry notice dated January 8, 2025, issued by the Directorate of Vigilance and Anti-Corruption (DVAC).

The enquiry was initiated following a letter from the Secretary of Labour Welfare, based on an anonymous complaint alleging financial irregularities and the collection of money from subordinates.

The petitioner argued that G.O.Ms.No.173 dated December 19, 2018, prohibits action on anonymous complaints.

While the writ was filed in April 2026, the DVAC had already concluded its enquiry in October 2025, finding one allegation substantiated and recommending departmental action.

1. Whether a preliminary enquiry by the DVAC initiated on the basis of an anonymous complaint is legally sustainable in light of G.O.Ms.No.173.

2. Whether the writ petition seeking to quash an enquiry notice is maintainable after the enquiry has been concluded and a recommendation for disciplinary action has been made.

G.O.Ms.No.173, Personnel and Administrative Reforms (N) Department (19.12.2018), which states that no action should be taken on anonymous complaints to protect officials from harassment.

Section 17A of the Prevention of Corruption Act, 1988, and Para 129 of the Vigilance Manual, which mandates the DVAC to collect intelligence regarding corrupt activities.

DVAC Standing Order No.30/76 (28.12.1976), which permits verification of specific, verifiable information even in anonymous petitions.

The Court reasoned that guidelines in G.O.Ms.No.173 are recommendatory, not mandatory, and do not absolute-prohibit the Vigilance Department from verifying specific allegations of bribery.

It noted that the complaint, though anonymous, contained specific details regarding the demand and transfer of money to the petitioner’s account, which justified the Department Head’s decision to seek a verification.

The Court found that the DVAC concluded its enquiry on October 28, 2025—finding suspicious bank transactions substantiated—well before the petitioner approached the Court in April 2026.

Consequently, the Court viewed the petition as an attempt to scuttle pending disciplinary proceedings rather than a bona fide challenge to a procedural error.

The Court held that since the enquiry report was already submitted and the Vigilance Commissioner had recommended departmental action by February 2026, the challenge to the initial notice was infructuous.

The Court directed the departmental proceedings to reach their logical end in accordance with the law.