Termination of a probationer for unsatisfactory performance after multiple opportunities to improve constitutes termination simpliciter, not punishment.

The petitioner was appointed as Assistant (General) Grade-III at the Central Leather Research Institute (CLRI) on 19.08.2015, subject to a one-year probation period.

His probation was extended twice via Office Memorandums dated 04.10.2016 and 17.05.2017 due to unsatisfactory performance, specifically citing non-completion of assigned tasks and discourteous behavior.

Ultimately, his services were terminated on 10.09.2017 under Clause 13(1) of his appointment letter.

The petitioner challenged this termination before the Central Administrative Tribunal (CAT), Chennai, which dismissed his application (OA No. 428 of 2018) on 25.03.2025.

The petitioner subsequently filed this Writ Petition to quash the CAT order and seek reinstatement.

1. Whether the termination of the petitioner’s services during the probationary period without a one-month notice period was in violation of the terms of the appointment letter.

2. Whether the termination of a probationer for unsatisfactory performance constitutes a 'punitive' or 'stigmatic' action requiring a formal inquiry.

The Court applied the principle of 'termination simpliciter' regarding probationary employment.

Clause 13(1) of the appointment letter, which permits termination during probation "at any time without notice and without assigning any reasons".

The precedent established by the Hon’ble Supreme Court in Ajit Singh v. State of Punjab (1983) 2 SCC 21, which holds that termination due to a probationer's unsatisfactory performance is not ipso facto 'stigmatic' or 'punitive'.

The rule dictates that an employer is obligated to assess a probationer’s suitability, and if found unfit, may terminate the service without it being deemed a penalty.

The Court rejected the petitioner’s argument that a one-month notice was mandatory, pointing out that Clause 13(1) of the specific appointment order explicitly allowed for termination without notice during the probationary period.

The Court observed that the respondents had provided the petitioner with ample opportunity to improve by extending his probation twice and issuing warnings regarding specific shortcomings, such as non-completion of service verifications and discourteous behavior.

By applying the Ajit Singh doctrine, the Court reasoned that since the termination was based on a subjective assessment of the petitioner's performance during his trial period, it remained a 'termination simpliciter'.

The Court found that the authorities followed due procedure as per the contract of service, and the lack of improvement by the petitioner justified the invocation of the termination clause.

It concluded that the termination was valid as it was performed in accordance with the terms of the appointment and established legal principles governing probationers.

The High Court dismissed the Writ Petition and all connected miscellaneous petitions, denying the relief of reinstatement or continuity of service.