Denied factual allegations require a departmental inquiry, even before imposing a minor penalty.

The petitioner, then working as an In-charge Sub-Registrar, performed registration duties on 12 April 2012.

Following a complaint, a fact-finding inquiry was conducted and show-cause notices were issued.

The petitioner denied the allegations and submitted replies.

Without holding a regular departmental inquiry, the disciplinary authority ordered withholding of three annual increments without cumulative effect on 20 January 2014.

The petitioner’s appeal was dismissed on 7 September 2015.

Whether the respondents could impose a minor penalty on the basis of a fact-finding inquiry and the petitioner’s reply to a show-cause notice when he specifically denied the factual allegations.

Whether the punishment and appellate orders could stand where no regular departmental inquiry was held to determine the disputed facts.

In O.K. Bhardwaj v. Union of India, (2001) 9 SCC 180, the Supreme Court held that although withholding increments may be a minor penalty, where the employee denies factual charges, an inquiry is required as a minimum requirement of natural justice.

A fact-finding inquiry may establish a basis for disciplinary action but does not, by itself, constitute a regular departmental inquiry proving disputed charges.

The Court also relied on Manmohan Singh v. Home Department, W.P. No. 19843/2022, decided 15 September 2022, and Anurag Pratap Singh v. State of M.P., W.P. No. 19084/2023, decided 19 February 2025, which applied the same principle.

The petitioner specifically denied the allegations and raised factual grounds in detailed replies, creating a dispute that could not be resolved merely by relying on the fact-finding report and the show-cause process.

Because no regular departmental inquiry was conducted, the petitioner was not given an effective opportunity to meet the evidence or establish his defence.

The minor nature of the penalty did not dispense with that requirement, and the disciplinary authority’s consideration of the replies could not substitute for an inquiry into the disputed facts.

It allowed the petition and quashed both orders dated 20 January 2014 and 7 September 2015.

The respondents were directed to grant consequential benefits within three months of receiving a certified copy of the order.

The competent authority remained at liberty to take fresh action in accordance with applicable service rules, provided the petitioner receives a full opportunity to defend himself.