Post-retirement departmental proceedings cannot concern events occurring more than four years earlier.

The petitioner, a retired District Education Officer, retired from service on 31 January 2021.

The State issued a charge-sheet against him on 29 September 2025 concerning alleged financial irregularities said to have occurred in January 2021.

He challenged the charge-sheet, arguing that it was barred by the four-year limit in Rule 9(2)(b)(ii) of the Chhattisgarh Civil Services (Pension) Rules, 1976, and that the required sanction under Rule 9(2)(b)(i) had not been obtained.

The State did not dispute his retirement date.

1. Whether departmental proceedings instituted after the petitioner’s retirement were barred because they concerned an event more than four years before their institution.

2. Whether the proceedings could be instituted without the Governor’s sanction required by Rule 9(2)(b)(i).

Rule 9(2)(b) of the Chhattisgarh Civil Services (Pension) Rules, 1976 governs departmental proceedings instituted after a government servant’s retirement. Such proceedings may not be instituted without the Governor’s sanction and may not concern an event that took place more than four years before institution.

The Court cited no precedent.

The Court found that the petitioner retired on 31 January 2021 and that the charge-sheet was issued on 29 September 2025, after retirement.

It accepted that the alleged event occurred in January 2021 and concluded that the charge-sheet was issued more than four years after that event.

The proceedings therefore contravened Rule 9(2)(b)(ii) and were without jurisdiction.

Although the petitioner also challenged the absence of the required sanction, the Court did not separately determine that ground.