Threshold interference with charge-sheet is limited; mala fides or grave defect must be shown before quashing departmental proceedings.

A charge-sheet and departmental proceedings are ordinarily not interfered with at the threshold unless the action is wholly without jurisdiction, tainted by mala fides, or vitiated by a grave procedural defect. On the facts noted, the disciplinary authority had considered the employee's representation, recorded reasons, and dealt with the complaint material, investigation record, approval chain, and supply of relied-upon documents before issuing the charge-sheet. The file material showed no predetermination, bias, or illegality warranting judicial intervention. The employee's objections were treated as matters for determination in the departmental enquiry, so the charge-sheet was not quashed at the initial stage and the challenge failed.

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Issues: Whether the charge-sheet and initiation of departmental proceedings were liable to be quashed at the threshold on grounds of alleged procedural irregularity, mala fides, non-supply of documents, and lack of proper application of mind by the disciplinary authority.

Analysis: The challenge was examined in the context of settled law that courts and tribunals ordinarily do not interfere with a charge-sheet or disciplinary proceedings at the initial stage. Interference is justified only where the proceedings are shown to be wholly without jurisdiction, vitiated by mala fides, or infected by a grave statutory or procedural defect capable of destroying the process. The record disclosed that the disciplinary authority had considered the representation, recorded reasons, and found no substance in the objections. The complaints, investigation material, approval chain, and the supply of relied upon documents were all dealt with before issuance of the charge-sheet. The Tribunal also found nothing in the summoned files to show predetermination, bias, or such illegality as would warrant judicial interference. The applicant's grievances were held to be matters to be tested in the departmental enquiry.

Conclusion: The charge-sheet was not liable to be quashed at the threshold, and the Original Application failed.

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