Disciplinary charge sheets cannot ordinarily be challenged before the inquiry concludes.

A complaint dated 30 March 2015 alleged that, during 2012–13, two borewells intended for Lingsugur Taluk were drilled in Kushtagi Taluk; bills of ₹3,00,000 were settled without an agreement; and substandard materials were used.

The Lokayukta investigated under Section 9 of the Karnataka Lokayukta Act, 1984 and submitted a report under Section 12(3), after which the State Government entrusted a disciplinary enquiry under Rule 14(A) of the Karnataka Civil Services (Classification, Control and Appeal) Rules, 1957.

The Lokayukta then issued articles of charge dated 12 May 2017.

Maidunnisa challenged the entrustment order and charges before the Karnataka State Administrative Tribunal, which allowed his application on 23 August 2021, finding the entrustment order unsupported by proper application of mind and the charges insufficiently specific.

The Karnataka Lokayukta challenged that decision by writ petition.

1. Whether the Tribunal could quash the enquiry-entrustment order and articles of charge at the threshold, including by assessing the specificity or evidentiary sufficiency of the charges

2. Whether the complaint was barred under Section 8(2)(c) or Section 8(2)(d) of the Karnataka Lokayukta Act, 1984

Ordinarily, courts and tribunals should not interfere with a charge-sheet or show-cause notice before the disciplinary process concludes, because its issuance alone does not infringe the charged employee’s rights; intervention may be justified in exceptional cases, such as where the issuing authority lacks jurisdiction or competence, or the charge-sheet is wholly illegal.

The Court applied Union of India v. Kunisetty Satyanarayana, (2006) 12 SCC 28, and Secretary, Ministry of Defence v. Prabhash Chandra Mirdha, (2012) 11 SCC 565, including the principles that the truth or correctness of charges is ordinarily for the disciplinary authority to determine and that a charge-sheet should not be quashed routinely.

Under Section 8(2)(c) of the Karnataka Lokayukta Act, a complaint involving a grievance must ordinarily be made within six months of the complainant learning of the action; under Section 8(2)(d), a complaint involving an allegation must ordinarily be made within five years of the action complained of.

The proviso permits the Lokayukta or Upalokayukta to entertain a late complaint where sufficient cause is shown.

The enquiry was entrusted under Rule 14(A) of the KCS (CCA) Rules following a report under Section 12(3) of the Act.

The Court held that the Tribunal had prematurely assessed the charges, the material supporting them, and Maidunnisa’s alleged role—matters to be examined during the disciplinary enquiry.

Maidunnisa could raise his objections and present evidence in that process; the charges did not fall within an established exception warranting threshold judicial intervention.

On limitation, the Court characterised the complaint as one involving allegations of misappropriation and irregularities, rather than a grievance governed by the six-month period in Section 8(2)(c).

The alleged events occurred in 2012–13 and the complaint was made on 30 March 2015, within the five-year period in Section 8(2)(d); the Court therefore rejected the limitation objection.

It also rejected the argument that proceedings against Maidunnisa were invalid because other officials were not proceeded against, observing that there is no doctrine of negative equality.

The entrustment of the enquiry and the articles of charge were therefore left in place for the disciplinary proceedings to continue.