KCSR bars post-retirement disciplinary proceedings concerning events more than four years before institution.

The petitioner, a retired Regional Manager of the respondent Corporation, challenged Articles of Charges issued on 5 February 2026 concerning his alleged failure, while serving as Warehouse Manager at Bannuru, to take steps to recover rent due from the Karnataka Food and Civil Supplies Corporation for the period 2012–2017.

The Corporation had withheld his superannuation benefits on the same ground.

In an earlier writ petition, the High Court quashed the withholding order and directed the Corporation to consider the petitioner’s representations, while observing that departmental proceedings could be initiated if permitted by law.

The petitioner then challenged the subsequent Articles of Charges and sought release of his retirement benefits, with interest.

Whether departmental proceedings initiated after the petitioner’s retirement, concerning events from 2012 to 2017, were barred by Rule 214(2)(b)(ii) of the Karnataka Civil Services Rules (KCSR)

Whether the petitioner was entitled to release of his pending superannuation benefits and interest

Rule 214(2)(b)(ii) of the KCSR provides that departmental proceedings not instituted while a government servant was in service cannot, after retirement, relate to an event that took place more than four years before institution of the proceedings.

The Corporation had adopted the KCSR and the Karnataka Civil Services (Classification, Control and Appeal) Rules for its employees.

Liberty granted in an earlier order to initiate proceedings is conditional: proceedings may be initiated only to the extent permitted by law.

The Court treated the date on which the Articles of Charges were framed—5 February 2026—as the date of institution of the proceedings.

Because the charges concerned alleged lapses between 1 January 2012 and 18 January 2017, the events fell outside the four-year limit in Rule 214(2)(b)(ii).

The Court rejected the Corporation’s argument that the failure to recover rent constituted a continuing cause of action, reasoning that the alleged lapse related to the petitioner’s conduct during 2012–2017 and proceedings should have been initiated within a reasonable time after the lapse was noticed.

The earlier order’s liberty to initiate an enquiry did not permit proceedings contrary to the statutory bar.

The Court also noted that the Corporation had already withheld the benefits on the same ground and initiated proceedings only after the earlier order.

It set aside the Articles of Charges and the enquiry proceedings and directed the Corporation to release all pending superannuation benefits.

In view of the Corporation’s submission and memo undertaking payment within three months, the Court recorded that undertaking and rejected the petitioner’s request for interest.