Termination without notice or enquiry report violates natural justice and warrants judicial intervention despite an alternative remedy.

The petitioner was appointed on a contractual basis as an Assistant Coach/Weightlifter Trainer in Weightlifting at the Khelo India Centre of Excellence, Patna, Bihar.

Following a surprise inspection at the State Sports Academy, Rajgir, Nalanda, certain irregularities were allegedly detected, including the presence of banned medicines and injections. An enquiry was thereafter conducted, culminating in the petitioner’s termination through Memo No. 3088 dated 20 June 2026, issued by the Deputy Director, Bihar State Sports Authority.

The petitioner challenged the termination on the ground that he was neither served with the enquiry report nor issued a notice or granted an opportunity of hearing before the adverse order was passed.

The State objected to the maintainability of the writ petition, contending that the petitioner had an alternative remedy before the Director General, Sports Authority of India, under the terms of his offer letter.

1. Whether the petitioner’s termination was invalid for violation of the principles of natural justice, particularly because the enquiry report was not supplied and no adequate opportunity of hearing was provided?

2. Whether the availability of an alternative remedy barred the petitioner from invoking the writ jurisdiction of the High Court under Article 226 of the Constitution?

The Court applied the principles of natural justice, including the requirements that a person facing adverse action must receive notice of the allegations/material relied upon, be supplied with the enquiry report, and be afforded a meaningful opportunity of hearing before a final decision is taken.

The Court further applied Article 226 of the Constitution, holding that the existence of an alternative remedy does not ordinarily bar writ jurisdiction where the impugned action is prima facie arbitrary or has been taken in breach of natural justice.

The Court examined the impugned termination order and found, prima facie, that the petitioner had not been served with a notice accompanied by the enquiry report and that the final decision had not been passed after considering any response from him.

These procedural deficiencies amounted to a complete violation of the principles of natural justice and rendered the termination arbitrary.

Although the State relied on the alternative remedy stipulated in the offer letter, the Court held that such remedy could not prevent judicial review where the foundational procedural safeguards had not been followed.

The Court therefore addressed the writ petition on its merits rather than relegating the petitioner to the alternative forum.

The order was accordingly set aside. The matter was remitted to the concerned authority with directions to issue the petitioner a fresh notice along with the enquiry report, provide him a proper opportunity of hearing, and thereafter pass a reasoned and speaking order in accordance with law.

The entire exercise was directed to be completed preferably within three months.

The writ petition was allowed to that extent.