Contractual termination after an opportunity to explain does not violate natural justice absent decision-making illegality.

The petitioner was appointed as an Additional Programme Officer on contract basis on 19 April 2017 and was subsequently entrusted with additional responsibilities and promoted as Assistant Programme Officer by order dated 13 March 2025. His contractual engagement was stated to continue until 31 March 2026. On 27 May 2025, the Collector, Sagar issued a show-cause notice alleging misconduct, indiscipline, negligence in the discharge of duties, lack of interest in work, and failure to improve his working system. The petitioner submitted his explanation on 9 June 2025. Finding the explanation unsatisfactory, the Collector terminated his contractual services on 23 June 2025

The petitioner initially approached the High Court in W.P. No. 28093/2025, which was disposed of with liberty to pursue an alternative appeal before the Commissioner, M.P. State Employment Guarantee Council. The Commissioner thereafter rejected the petitioner’s appeal/representation and affirmed the termination order on 16 December 2025

The petitioner challenged the Commissioner’s order under Article 226 of the Constitution, alleging that the termination was stigmatic and punitive and that he had been granted only three days to respond to the show-cause notice, contrary to natural justice

Whether the termination of the petitioner’s contractual engagement, allegedly founded on misconduct and other stigmatic grounds, required a regular departmental enquiry

Whether the proceedings violated the principles of natural justice because the petitioner was allegedly granted only three days to respond to the show-cause notice

Whether the Collector’s termination order and the Commissioner’s appellate order disclosed any illegality, arbitrariness, perversity, jurisdictional error, or breach of a mandatory statutory or contractual provision warranting interference under Article 226

The Court applied the principle that a contractual employee cannot claim all the statutory protections available to a regularly appointed government servant merely because the contractual term remains subsisting; continuation is subject to the applicable contractual conditions

It further applied the principles of natural justice, holding that an opportunity to know the allegations and submit an explanation is material, and that the mere grant of a short period does not, by itself, establish violation where the employee in fact submitted a reply and the authority considered it

In judicial review under Article 226, the Court’s primary concern is the legality of the decision-making process, including illegality, arbitrariness, perversity, violation of natural justice, or breach of a mandatory statutory or contractual provision; it does not ordinarily reappreciate the merits of the administrative conclusion

The petitioner relied on Swati Priyadarshini v. State of Madhya Pradesh, 2024 SCC OnLine SC 2139, and the decisions in Rahul Tripathi v. Rajeev Gandhi Shiksha Mission, Bhopal, 2001 (3) MPLJ 616, and Rajendra Kumar v. State of M.P., 2017 (4) MPLJ 547

The Court found that the petitioner was a contractual employee and therefore could not invoke, merely by reason of the remaining contractual period, the full procedural protections applicable to a regular government servant

The show-cause notice disclosed the allegations, and the petitioner admittedly submitted his explanation on 9 June 2025. Since the record did not show that the competent authority refused to consider that explanation, the Court held that the alleged three-day period, by itself, did not establish denial of natural justice

The conclusion that the explanation was unsatisfactory was treated as an administrative assessment by the competent authority, and the petitioner failed to demonstrate any jurisdictional error, perversity, arbitrariness, or breach of a mandatory contractual or statutory requirement. Accordingly, the limited scope of judicial review did not permit interference with either the termination order or the Commissioner’s reasoned appellate decision

The writ petition was dismissed, and the Commissioner’s order dated 16 December 2025 affirming the Collector’s termination order dated 23 June 2025 was left undisturbed. No order as to costs was made