Chhattisgarh High Court
Employment and Labour LawAdministrative and Public Law

Long-pending departmental inquiry must conclude within six months after supplying relied-upon documents and providing a fair hearing.

RAM PRASAD, vs SOUTH EASTERN COALFIELDS LTD.

Chhattisgarh High CourtJUDGMENT: October 06, 20262 MIN READSOURCE JUDGMENT
Long-pending departmental inquiry must conclude within six months after supplying relied-upon documents and providing a fair hearing.. RAM PRASAD, vs SOUTH EASTERN COALFIELDS LTD.. Chhattisgarh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

In W.P.(S) No. 5976 of 2017, the petitioner challenged the initiation of a departmental enquiry, alleging that he had not been supplied with the charge-sheet, witness list, or relied-upon documents.

Source reference: para. 1, 3

The enquiry arose from a charge-sheet dated 24 February 2017 concerning the alleged use of a false name to obtain employment with SECL.

Source reference: para. 1, 3

The High Court stayed further enquiry proceedings on 10 November 2017.

Source reference: para. 2

SECL later filed a return attaching the charge-sheet and the petitioner’s reply to the Enquiry Officer dated 6 March 2017.

Source reference: para. 4

In W.P.(S) No. 3697 of 2020, another petitioner claimed that the first petitioner had obtained employment in his name and sought continuation of the enquiry.

Source reference: para. 8
02

Issues

Whether the interim stay of the departmental enquiry should remain in force where SECL had produced the charge-sheet and the enquiry had remained pending for nearly nine years.

Source reference: para. 4, 6

Whether W.P.(S) No. 3697 of 2020 remained maintainable once the Court directed the enquiry to proceed expeditiously.

Source reference: para. 8–9
03

Law Applied

The Court proceeded under Article 226 of the Constitution of India and applied the principles of natural justice to the conduct of the departmental enquiry.

Source reference: para. 6

It directed that the petitioner receive a proper opportunity of hearing and copies of the documents on which SECL intended to rely.

Source reference: para. 6

The order cites no specific statutory provision or judicial precedent.

Source reference: no citation
04

Reasoning

SECL’s return included the charge-sheet and the petitioner’s earlier reply, addressing the petitioner’s claim that no charge-sheet had been issued.

Source reference: para. 4

Given that the enquiry had been pending for nearly nine years following the interim stay, the Court considered it appropriate to vacate the stay and require the enquiry to be completed within six months, subject to compliance with natural justice and supply of relied-upon documents.

Source reference: para. 6

Because that direction addressed the request for continuation of the enquiry made in W.P.(S) No. 3697 of 2020, the Court found that petition had become infructuous.

Source reference: para. 8–9
05

Holding

The Court vacated the interim order in W.P.(S) No. 5976 of 2017 and directed the Enquiry Officer to complete the enquiry within six months of receiving the order, after providing a proper hearing and the documents SECL intended to rely upon.

The petitioner was directed not to delay the proceedings.

Source reference: para. 6–7, 11

That petition was disposed of without any finding on the merits of the allegations.

Source reference: para. 6–7, 11

W.P.(S) No. 3697 of 2020 was disposed of as infructuous, and pending interlocutory applications were also disposed of.

Source reference: para. 9–10
Chhattisgarh High Court

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RAM PRASAD,vsSOUTH EASTERN COALFIELDS LTD.

Chhattisgarh High Court · October 06, 2026

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