CAT - ['Allahabad']

Scope of Judicial Review Narrowly Confined to Procedural Regularity and Correctness of Process in Departmental Inquiry.

FATEH CHANDRA vs Union Of India

CAT - ['Allahabad']JUDGMENT: April 23, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant, a Senior Section Engineer (Telecommunication) in the North Eastern Railway, challenged a major penalty charge sheet dated 07.07.2010

Source reference: p. 2

The applicant alleged that the charge sheet and frequent transfers were products of malice and professional harassment by respondent no. 6

Source reference: p. 2-3

The respondents contended that the applicant committed misconduct by abandoning his duty at Shyamkauriya Railway Station without permission, disobeying senior orders, and switching off his mobile phone after obtaining a sickness certificate

Source reference: p. 3-4

During the pendency of the litigation, the Inquiry Officer (respondent no. 5) was transferred, and a new officer was appointed

Source reference: p. 5-6

The applicant also sought the clearance of unpaid Travel Allowance (TA) for the period of June to August 2010

Source reference: p. 2
02

Issues

1. Whether the charge sheet dated 07.07.2010 and subsequent orders regarding the appointment of the Inquiry Officer were liable to be quashed on grounds of bias and procedural irregularity

Source reference: p. 2 / para. 3.4

2. Whether the Tribunal should interfere in the ongoing disciplinary proceedings before a final order of punishment is passed

Source reference: p. 7 / para. 9

3. Whether the applicant is entitled to the payment of outstanding Travel Allowance claims

Source reference: p. 2 / para. 2(iii)
03

Law Applied

Railway Servants (Discipline and Appeal) Rules, 1968, which govern the procedure for inquiries and the appointment of Inquiry Officers

Source reference: p. 4, 7

S.R. Tewari v. Union of India (2013), which holds that courts should not substitute their own findings for those of the disciplinary authority nor re-appreciate evidence unless the order is without jurisdiction or suffers from a "shocking" procedural irregularity

Source reference: p. 7-8
04

Reasoning

The Tribunal observed that the disciplinary proceedings were still at the inquiry stage and no final punishment had been imposed

Source reference: p. 7

Regarding the allegation of bias, the court noted that the original Inquiry Officer (Deepak Verma) had been transferred and replaced by a new officer, thereby resolving the applicant's primary grievance regarding a biased hearing

Source reference: p. 7

The Tribunal found that the disputes regarding duty assignment and medical leave were factual matters to be determined during the inquiry rather than through judicial review

Source reference: p. 7

Applying the S.R. Tewari precedent, the Tribunal reasoned that quashing the charge sheet prematurely would be "pre-empting the inquiry," which is impermissible as long as the process remains jurisdictionally sound

Source reference: p. 7-8

Acknowledging that the case had been pending since 2011, the court determined that a time-bound conclusion was necessary to serve the interests of justice

Source reference: p. 7, 9
05

Holding

The Tribunal declined to quash the charge sheet or the impugned orders. It held that the scope for interference is restricted to exceptional cases involving a lack of jurisdiction or gross procedural illegality, neither of which were conclusively proven at this stage

The Original Application was disposed of with a direction to the respondents to complete the disciplinary proceedings in accordance with the 1968 Rules within six months, provided the applicant cooperates. The interim order of status quo was discharged

Source reference: p. 8, 9
CAT - ['Allahabad']

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FATEH CHANDRAvsUnion Of India

CAT - ['Allahabad'] · April 23, 2026

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