No pre-decisional hearing is required before recovering police training expenses under P.M. Rule 665.

The petitioner, initially appointed as a Sipahi in the Bihar Special Armed Police (BSAP), was subsequently selected for appointment as a Government school teacher.

Upon seeking resignation and a No Objection Certificate (NOC), the respondents required him to deposit ₹4,70,169 towards the expenditure incurred on his training. The demand was made through Memo No. 3892 dated 7 December 2023, and a further amount of ₹10,465 was subsequently recovered pursuant to communication dated 20 November 2024.

The petitioner challenged the recovery, sought production of the statutory authority for the demand, quashing of consequential recovery proceedings, and refund with interest. The State relied on P.M. Rule 665, stating that the amount spent on the petitioner’s training was recoverable and that the requirement was mentioned in the NOC issued through Memo No. 3772 dated 28 November 2023.

Whether the respondents were legally entitled under P.M. Rule 665 to recover from the petitioner the expenditure incurred on his Sipahi training as a condition connected with his resignation and issuance of the NOC.

Whether the recovery demand was liable to be quashed for want of a detailed calculation or tabular statement explaining the amount demanded.

Whether the petitioner was entitled to a prior opportunity of hearing before the recovery decision was made.

The Court applied P.M. Rule 665, as relied upon by the State, as the governing service provision authorising recovery of the amount spent on the petitioner’s training when the NOC was issued.

The Court further held that no provision had been shown under P.M. Rule 665 requiring that a prior opportunity of hearing must necessarily be granted before determining or recovering the training expenditure.

The Court noted that the petitioner challenged Memo No. 3892 and the consequential recovery proceedings, while the State relied on P.M. Rule 665 and the express stipulation contained in the NOC that the training expenditure was to be deposited.

Although the petitioner complained that the demand letters merely stated the amounts without providing a calculation or tabular basis, the Court did not find that contention sufficient to invalidate the recovery. It also rejected the request for an opportunity of hearing, observing that the petitioner had not established any requirement under P.M. Rule 665 for such a hearing before recovery. On that basis, the Court declined to interfere with the demand or its consequential effects.

It declined to quash Memo No. 3892 dated 7 December 2023, the subsequent recovery communications, or the recovery of ₹4,70,169 and ₹10,465. The writ petition was accordingly dismissed.