Rajasthan High Court’s Recent Decision: Ensuring Swift Justice in Disciplinary Inquiries

Delays in disciplinary inquiries have been a long-standing issue affecting employees in both government and private sectors. The Rajasthan High Court recently addressed this problem in the case of Sardar Mal Yadav v. State Elementary Education & Ors., where it emphasized the importance of timely disposal of inquiries and fixing accountability for delays.

Sardar Mal Yadav, a government employee, was served a charge sheet in 2011 as part of disciplinary proceedings. However, even after the inquiry was completed in 2014, no final order was passed. The petitioner retired on January 31, 2025, and due to administrative inaction, he was forced to approach the court to seek justice. The case highlighted the inefficiency of government authorities in handling disciplinary cases and the resulting hardship faced by employees.

The High Court strongly criticized the Disciplinary Authority’s failure to pass a final order despite the completion of the inquiry more than a decade ago. It relied on the Supreme Court’s judgment in Prem Nath Bali v. Registrar, High Court of Delhi & Ors. (AIR 2016 SC 101), which held that employers have a duty to conclude departmental inquiries in a reasonable timeframe to prevent undue hardship to employees. The court emphasized that delays should be avoided by both government and private employers, as unnecessary postponements impact the careers and financial well-being of employees.

The court also noted that many Officers-In-Charge of government cases were not fulfilling their duties as required under Rule 233 of the Rajasthan Law and Legal Affairs Department Manual, 1999. It directed the Chief Secretary of Rajasthan to take strict action to ensure timely disposal of inquiries and to improve accountability within government departments.

Ultimately, the court ruled in favour of Sardar Mal Yadav, highlighting the critical need for timely resolution of disciplinary inquiries. The judgment makes it clear that any delay forces employees to approach the courts for relief, which only adds to the overall delay and prolongs their hardship. This ruling sends a strong message to both government and private employers: it is essential to conclude inquiries promptly to avoid unnecessary judicial intervention. Employers must take proactive steps to ensure that once an inquiry is closed, the process does not stall, as further delays not only undermine the rights of employees but also delay the dispensation of justice.

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