Disciplinary Authorities cannot travel beyond the scope of allegations contained in the specific charge-sheet.

The respondent, an Assistant Teacher at MC Primary School, Moti Bagh, was on sanctioned leave from December 11 to December 13, 2015

On December 13, an unauthorized private function (kuan pujan) was held on the school premises

Upon returning late that night, the respondent heard noise and discovered the function but did not inform authorities until two days later

A charge-sheet was issued alleging "active connivance" with the organizers and failure to maintain integrity under CCS (Conduct) Rules

Following an inquiry, the Disciplinary Authority (DA) imposed a penalty of stoppage of two increments with cumulative effect

The respondent challenged this before the Central Administrative Tribunal (CAT), which quashed the penalty on July 7, 2025

The Municipal Corporation of Delhi (MCD) filed this writ petition against the CAT’s order

1. Whether the findings of the Inquiry Officer (IO) and Disciplinary Authority (DA) could be sustained when they traveled beyond the specific allegations contained in the charge-sheet.

2. Whether there was sufficient evidence to prove the charge of "active connivance" as alleged in the charge-sheet.

The court applied the fundamental principle of administrative law that a Disciplinary Authority cannot travel outside the scope of the specific allegations contained in the charge-sheet

Rule 3(I)(i), (ii), and (iii) of the CCS (Conduct) Rules, 1964, regarding the maintenance of absolute integrity and devotion to duty

The Court observed that while the charge-sheet specifically alleged "active connivance" with the organizers and attending the party, the Inquiry Officer's (IO) findings merely established that the respondent visited the site upon hearing noise after returning from leave

The IO found no evidence of connivance but instead faulted the respondent for failing to stop the party, failing to lodge an FIR, or failing to inform higher authorities immediately—allegations that were notably absent from the original charge-sheet

The Court reasoned that since the DA's findings were based on lapses not charged to the respondent, the disciplinary action was procedurally and legally flawed

The Court further held that the Tribunal correctly identified that it should not sit in appeal over evidence unless the findings lack a basis in the specific charges framed

The High Court dismissed the writ petition and upheld the Tribunal’s order quashing the disciplinary and appellate orders. Consequently, the respondent is entitled to all consequential benefits