Chhattisgarh High Court
Employment and Labour LawAdministrative and Public Law

Salary deduction cannot stand without considering the employee’s response to a show-cause notice.

SMT. SANTOSHI NIRMALKAR vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: October 13, 20261 MIN READSOURCE JUDGMENT
Salary deduction cannot stand without considering the employee’s response to a show-cause notice.. SMT. SANTOSHI NIRMALKAR vs STATE OF CHHATTISGARH. Chhattisgarh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioners, Rural Health Organizers, challenged the deduction of one day’s salary from each of them for June 2025 for failing to make vaccination-related entries on the U-WIN Portal.

Source reference: para. 2

After show-cause notices were issued on 28 May 2025, the petitioners submitted replies explaining, among other things, that they had not received adequate training in computer operations and data entry.

Source reference: para. 3

The Court considered only relief clause 10.4, as the petitioners did not press relief clauses 10.2 and 10.3; clauses 10.1 and 10.5 were described as formal.

Source reference: para. 1
02

Issues

Whether the respondents could deduct one day’s salary without duly considering the petitioners’ replies to the show-cause notices.

Source reference: paras. 3, 6–7

Whether the petitioners were entitled to reconsideration of the deduction and a reasoned decision on their explanations.

Source reference: para. 8
03

Law Applied

The Court applied the principle of natural justice that, where an employee has submitted a reply to a show-cause notice, the authority must consider that explanation and pass an appropriate order in accordance with law before taking consequential action.

Source reference: paras. 7–9

The judgment cited no specific statute or precedent.

Source reference: no citation
04

Reasoning

The Court found that the petitioners had submitted replies to the notices, but that the respondents had not duly considered those explanations before deducting salary.

Source reference: para. 6

Because the deduction followed without that consideration, the action could not be sustained; the respondents were therefore required to assess the replies and issue fresh, reasoned orders.

Source reference: paras. 7–8

The Court expressly left the merits of the explanations undecided.

Source reference: para. 9
05

Holding

The writ petition was allowed to the extent considered.

The respondents were directed to consider the petitioners’ replies and pass fresh, reasoned orders concerning the salary deductions in accordance with law; if the explanations were found satisfactory, the deducted amounts were to be refunded in accordance with law.

Source reference: paras. 8–10
Chhattisgarh High Court

Original Court PDF

SMT. SANTOSHI NIRMALKARvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · October 13, 2026

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