Supreme Court emphasizes prima facie case for CBI inquiry, upholds exhaustion of alternate remedies

The Supreme Court set aside a High Court order directing a CBI inquiry against a Minister without establishing a prima facie case, emphasizing the need for definite findings before such investigations. The Court highlighted that the High Court had not adequately considered the Minister's response before ordering the inquiry. Additionally, the Court upheld the High Court's decision to relegate a petitioner to the U.P. Public Service Tribunal for remedy, emphasizing the importance of exhausting alternate remedies before seeking relief under Article 226. The Court dismissed the appeals challenging the tribunal's lack of interim relief powers.

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Issues Involved:
1. High Court directing CBI inquiry against Minister without prima facie case.
2. Relegation of petitioner to U.P. Public Service Tribunal.

Issue 1: High Court directing CBI inquiry against Minister without prima facie case:
The Supreme Court considered appeals arising from a High Court order directing a Central Bureau of Investigation (CBI) inquiry against a Minister without establishing a prima facie case. The High Court's decision was challenged on the grounds that there was insufficient material to warrant such an inquiry. The Court emphasized that the power to direct a CBI inquiry under Article 226 must be based on a prima facie conclusion supported by material on record, not just allegations. Referring to the Common Cause case, the Court highlighted the need for a definite finding before ordering a CBI investigation. The Court noted that the High Court had not adequately considered the Minister's reply before directing the inquiry, leading to the decision to set aside the High Court's judgment and remand the matter for further consideration.

Issue 2: Relegation of petitioner to U.P. Public Service Tribunal:
In another appeal, the Supreme Court addressed the High Court's decision to relegate a petitioner to the U.P. Public Service Tribunal for remedy, despite the tribunal lacking the power to grant interim orders. The petitioner argued that the tribunal's inability to provide interim relief rendered the remedy illusory. However, the Court disagreed, stating that the existence of an alternate remedy, even without interim relief powers, did not justify bypassing the tribunal. The Court emphasized that petitioners should first seek recourse through the established tribunal process before considering Article 226 relief. Consequently, the Court upheld the High Court's decision to direct the petitioner to approach the tribunal, dismissing the appeals.

Separate Judgment:
In a separate judgment, the Court disposed of additional petitions in light of a previous judgment, indicating no further orders were necessary.

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