Facts
NALCO issued the petitioner a show-cause notice dated 15 December 2025 concerning alleged conduct that could result in action under the work-order clauses, including termination.
Source reference: paras. 1–3; pp. 1–2The petitioner was subsequently debarred from doing business with NALCO for 12 months by an order dated 18 August 2026.
Source reference: paras. 1–3; pp. 1–2It challenged that order, contending that the notice had not stated that blacklisting or debarment was contemplated.
Source reference: paras. 1–3; pp. 1–2Issues
1. Whether a show-cause notice contemplating action concerning termination of a work order, but not expressly or clearly indicating possible blacklisting or debarment, can support a subsequent debarment order
Source reference: paras. 1–3, 9–10; pp. 1–3, 8–92. Whether the debarment order was liable to be quashed for failure to provide adequate notice and a meaningful opportunity to respond to the proposed blacklisting
Source reference: paras. 5–6, 9–10; pp. 3–4, 8–9Law Applied
Under the principles of natural justice, a show-cause notice must state the grounds for the proposed action and the action or penalty contemplated with sufficient clarity to enable an informed response; an order cannot travel beyond the notice
Source reference: paras. 5–6; pp. 3–6In blacklisting cases, the notice must clearly state, expressly or by necessary implication, that blacklisting is contemplated, given its serious civil and reputational consequences
Source reference: para. 6; pp. 5–6The Court also relied on M/s. Konark Ayurvedic Pharmacy v. State of Odisha, W.P.(C) No. 10170 of 2026, and M/s. A.K.G. Construction and Developers Pvt. Ltd. v. State of Jharkhand, 2026 INSC 312, for the principle that termination and blacklisting are distinct actions and that blacklisting requires a specific notice and separate consideration
Source reference: paras. 7–8; pp. 6–7A breach of these requirements may be corrected in the High Court’s jurisdiction under Article 226
Source reference: para. 6; p. 4Reasoning
The Court read the show-cause notice as contemplating action relating to termination of the work order, not exclusion from future contracts.
Source reference: paras. 3–6, 9–10; pp. 2–5, 8–9The contractual clauses relied on by NALCO did not, without more, make blacklisting a clearly notified consequence.
Source reference: paras. 3–6, 9–10; pp. 2–5, 8–9Applying UMC Technologies and the other cited authorities, the Court held that the petitioner had not been given notice of the distinct proposed action of debarment and therefore lacked a meaningful opportunity to answer it.
Source reference: paras. 3–6, 9–10; pp. 2–5, 8–9The debarment order consequently went beyond the notice and violated natural justice.
Source reference: paras. 3–6, 9–10; pp. 2–5, 8–9Holding
The Court held that the show-cause notice did not contemplate blacklisting or debarment and that the resulting order was contrary to the principles of natural justice.
It quashed and set aside the 18 August 2026 debarment order and disposed of the writ petition.
Source reference: para. 10–11; p. 9Original Court PDF
M/S. KARAN SINGH SECURITY AGENCY PVT. LTD., BHUBANESWARvsNALCO, BHUBANESWAR
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