Writ courts will not entertain grounds raised for the first time after disciplinary proceedings conclude.

The petitioner, a Sub-Inspector in the Central Industrial Security Force (CISF), joined service in June 2022.

In April 2025, he allegedly complained regarding the provision and use of transport facilities for CISF personnel and subsequently asserted that he was targeted by senior officers, including through denial or curtailment of leave.

On 17 October 2025, the Deputy Commandant initiated a preliminary enquiry against him, followed by framing of charges on 3 November 2025.

After disciplinary proceedings, the Assistant Commandant imposed the penalty of reduction of pay by one stage—from ₹38,700 to ₹37,600 in Pay Matrix Level-6—for one year.

The petitioner’s appeal and revision were dismissed on 24 January 2026 and 20 March 2026, respectively.

He therefore invoked Article 226 of the Constitution seeking quashing of the disciplinary proceedings and restoration of pay and consequential benefits.

1. Whether the disciplinary proceedings, including the preliminary enquiry, charge memorandum, penalty order, appellate order and revisional order, were vitiated by mala fides and motivated retaliation for the petitioner’s complaints against senior officers.

2. Whether the petitioner had established any procedural infirmity or illegality warranting interference by the High Court under Article 226 of the Constitution.

3. Whether the petitioner was entitled to restoration of his original pay stage and consequential arrears and service benefits.

The Court applied the constitutional power of judicial review under Article 226, under which interference with disciplinary proceedings is justified where the decision-making process is illegal, procedurally unfair, or otherwise vitiated by a demonstrable legal infirmity; the writ court does not ordinarily re-appreciate disciplinary findings in the absence of such infirmity.

The Court also applied the principle that a party seeking writ relief must establish the grounds relied upon from the contemporaneous record and cannot ordinarily succeed on allegations or grounds not raised before the disciplinary, appellate or revisional authorities.

No specific statutory provision or judicial precedent was cited in the judgment.

The Court examined the disciplinary record and the petitioner’s response recorded in the final order.

It compared the petitioner’s complaint to the SHO, which principally concerned denial of leave, with the case advanced before the Court alleging retaliation for complaints regarding misuse of official vehicles and transport facilities.

The Court found that the latter allegations had not been raised during the disciplinary proceedings, appeal or revision.

When specifically asked whether the grounds urged in the writ petition had previously been taken, counsel for the petitioner could not provide a categorical answer.

Further, the petitioner could not identify any procedural illegality or infirmity in the disciplinary process.

Consequently, the allegations of mala fides, unsupported by the earlier record and not demonstrating a legal defect in the proceedings, did not justify exercise of the Court’s extraordinary jurisdiction under Article 226.

The writ petition challenging the preliminary enquiry, charge memorandum, penalty, appellate order and revisional order was dismissed, and the consequential claim for restoration of pay, arrears and benefits was thereby rejected.

All pending applications were also disposed of.