CAT - ['Guwahati']

Disciplinary penalty upheld where the inquiry complied with natural justice.

SHRI DHANRAJ LAMA vs MSME

CAT - ['Guwahati']JUDGMENT: September 16, 20262 MIN READSOURCE JUDGMENT
Disciplinary penalty upheld where the inquiry complied with natural justice.. SHRI DHANRAJ LAMA vs MSME. CAT - ['Guwahati']. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant, an Executive with the Khadi and Village Industries Commission (KVIC), faced disciplinary proceedings concerning bills and vouchers allegedly processed while he was a Dealing Assistant at KVIC’s Itanagar office between 2011 and 2014.

Source reference: p.3

The charge concerned recommended payments totalling approximately ₹33,000; the inquiry treated a ₹25,000 bill as false and could not verify bus-ticket claims totalling ₹9,000 because the relevant witnesses did not appear.

Source reference: pp.3–5

The applicant denied processing the ₹25,000 bill and challenged the inquiry findings, including the adequacy of access to documents and the absence of supporting evidence for the remaining amount.

Source reference: pp.4, 9–11

The Disciplinary Authority imposed a reduction by one increment for two years without cumulative effect and ordered recovery of ₹25,000; the appeal was rejected. The applicant sought to quash the inquiry report, penalty order and appellate decision.

Source reference: pp.3, 5, 8–9
02

Issues

1. Whether the inquiry report and penalty order were liable to be set aside for want of evidence, inadequate consideration of the applicant’s defence, or breach of procedural fairness.

Source reference: pp.9–12

2. Whether the appellate decision rejecting the applicant’s appeal disclosed any legal infirmity warranting the Tribunal’s interference.

Source reference: pp.5, 10–12
03

Law Applied

The Tribunal referred to Regulation 10 of the KVIC Employees (CCA) Regulations, 2003, as governing the disciplinary inquiry and the provision of a reasonable opportunity to the charged employee.

Source reference: p.12

It also referred to Regulations 23 and 24: Regulation 23 was identified as conferring appellate powers on the Chairman, while Regulation 24 was cited in connection with communication of the appellate decision by the Chief Executive Officer.

Source reference: pp.7–8, 12

The Tribunal stated that judicial interference was not warranted where the disciplinary and appellate authorities had followed the prescribed process, considered the relevant material and acted for sufficient reasons.

Source reference: pp.12–13
04

Reasoning

The applicant argued that the ₹25,000 bill had not been processed by him, that the Presenting Officer’s brief supported his position on that bill, and that the ₹9,000 in bus-ticket claims remained unverified.

Source reference: pp.9–11

The Tribunal, however, concluded generally that the inquiry complied with Regulation 10, that the applicant had received reasonable opportunities, and that the Disciplinary Authority had considered the inquiry findings, his reply and the material on record.

Source reference: p.12

It likewise accepted that the appellate authority had considered the matter and found no infirmity in rejecting the appeal.

Source reference: p.12

The decision does not separately assess the disputed evidence concerning each bill, the applicant’s objection to the appellate order’s signature, or the asserted delay in initiating proceedings.

Source reference: no citation
05

Holding

The Tribunal held that the impugned orders did not warrant interference and dismissed the application as misconceived.

The penalty—including the two-year reduction by one increment without cumulative effect and recovery of ₹25,000—therefore remained in force; pending applications were disposed of, any interim order was vacated, and no costs were awarded.

Source reference: pp.3, 13
CAT - ['Guwahati']

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SHRI DHANRAJ LAMAvsMSME

CAT - ['Guwahati'] · September 16, 2026

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