CAT - ['Delhi']
Employment and Labour LawAdministrative and Public Law

Departmental inquiry must conclude within four months after affording cross-examination and relevant defence evidence opportunities.

Surendra Singhai vs HOUSING AND URBAN DEVELOPMENT CORPORATION (HUDCO)

CAT - ['Delhi']JUDGMENT: August 24, 20262 MIN READSOURCE JUDGMENT
Departmental inquiry must conclude within four months after affording cross-examination and relevant defence evidence opportunities.. Surendra Singhai vs HOUSING AND URBAN DEVELOPMENT CORPORATION (HUDCO). CAT - ['Delhi']. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant, a retired General Manager (Projects) of HUDCO, challenged, among other matters, the interlocutory orders dated 19 December 2025 and 10 July 2026 passed by the Inquiring Authority in a departmental inquiry initiated in 2012.

Source reference: para. 2

Two prosecution witnesses had been examined, but the applicant had not yet been given an opportunity to cross-examine them.

Source reference: para. 3

The applicant had also submitted a list of 31 defence witnesses, while the respondents contended that most were irrelevant to the inquiry.

Source reference: paras. 5–6

The departmental inquiry had remained pending for a considerable period.

Source reference: para. 9
02

Issues

Whether the applicant was entitled to an opportunity to cross-examine the two prosecution witnesses already examined in the departmental inquiry.

Source reference: para. 3

Whether the relevance of the applicant’s proposed defence witnesses should be determined by the Inquiring Authority.

Source reference: paras. 5–6

Whether the applicant was entitled to be generally questioned after completion of the defence evidence in accordance with the applicable rules.

Source reference: para. 7

Whether directions were necessary for expeditious completion of the departmental inquiry, which had been pending since 2012.

Source reference: para. 9
03

Law Applied

The Tribunal applied the principles of procedural fairness and natural justice governing departmental inquiries, including the right of a delinquent employee to cross-examine prosecution witnesses and to present relevant defence evidence.

Source reference: paras. 3–7

It accepted the parties’ agreed position that the Inquiring Authority would determine the relevance of the proposed defence witnesses and that the applicant would thereafter be generally questioned in accordance with the applicable service rules.

Source reference: paras. 6–7

The Tribunal further applied the principle that a long-pending disciplinary inquiry should be brought to its logical conclusion expeditiously and without unnecessary adjournments.

Source reference: para. 9
04

Reasoning

The respondents undertook, on instructions, to provide the applicant an opportunity to cross-examine the two prosecution witnesses, thereby addressing the principal procedural grievance.

Source reference: para. 4

As to the 31 defence witnesses, the Tribunal considered it appropriate for the Inquiring Authority, rather than the Tribunal at that stage, to assess their relevance; the parties agreed that this determination would be final.

Source reference: para. 6

The Tribunal also recorded the respondents’ undertaking that the applicant would be generally questioned after the defence evidence in accordance with the applicable rules.

Source reference: para. 7

Since these agreed measures addressed the grievances raised in the O.A., no surviving issue required adjudication on merits.

Source reference: para. 8

However, considering that the inquiry had been pending since 2012, the Tribunal imposed a four-month period for its completion.

Source reference: para. 9
05

Holding

The Tribunal disposed of the O.A. in terms of the parties’ agreed undertakings.

The applicant was to be afforded an opportunity to cross-examine the two prosecution witnesses; the Inquiring Authority was to decide the relevance of the proposed defence witnesses; and the applicant was to be generally questioned after completion of the defence evidence in accordance with the applicable rules.

Source reference: paras. 4, 6–7

The departmental inquiry was directed to be concluded within four months from receipt of a copy of the order, with neither party permitted to seek unnecessary adjournments.

Source reference: para. 9

No order as to costs was made.

Source reference: para. 10
CAT - ['Delhi']

Original Court PDF

Surendra SinghaivsHOUSING AND URBAN DEVELOPMENT CORPORATION (HUDCO)

CAT - ['Delhi'] · August 24, 2026

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