Reasonably practicable inquiry test upheld: intimidation and breakdown of discipline justified dismissal without departmental inquiry.

Dismissal without a departmental inquiry is valid only where the disciplinary authority records reasons showing that holding such inquiry is not reasonably practicable under Article 311(2)(b) and Rule 19. The test is reasonable practicability in the prevailing circumstances, not absolute impossibility, and judicial review is confined to whether the recorded reasons are relevant and bona fide. On the stated facts, intimidation, disruptive collective conduct, and a breakdown of discipline justified the conclusion that witnesses were unlikely to cooperate, so the dismissal orders were upheld as lawfully made.

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Issues: Whether the orders of dismissal passed without holding a departmental inquiry were validly made under clause (b) of the second proviso to Article 311(2) of the Constitution of India read with Rule 19 of the Central Civil Services (Classification, Control and Appeal) Rules, 1965, and whether the reasons recorded by the disciplinary authority showed that it was not reasonably practicable to hold such inquiry.

Analysis: The protection of Article 311(2) is withdrawn where one of the exceptions in the second proviso applies, and in the case of clause (b) the authority must be satisfied, for recorded reasons, that holding an inquiry is not reasonably practicable. The judgment reiterates that the test is one of reasonable practicability in the prevailing situation, not absolute impossibility, and that the court in judicial review examines whether the reasons are relevant and whether the power was exercised bona fide. On the facts, the employees' aggressive collective conduct, intimidation, disruption, and creation of an atmosphere in which witnesses were unlikely to cooperate justified the conclusion that a regular inquiry could not reasonably be held.

Conclusion: The dismissal orders were upheld as valid and clause (b) of the second proviso to Article 311(2) and Rule 19 were properly applied.

Ratio Decidendi: Where the disciplinary authority records reasons showing that, because of intimidation, violence, or a breakdown of discipline, a fair inquiry is not reasonably practicable, the constitutional safeguard of Article 311(2) is lawfully excluded and the resulting dismissal will be sustained unless the recorded reasons are irrelevant or mala fide.

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