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Issues: Whether the removal of members of the Electricity Board under Section 10(1)(e)(iv) of the Electricity (Supply) Act, 1948 was valid where the orders did not disclose the established charges and one order rested on a ground not put to the affected member.
Analysis: Removal under Section 10(1)(e)(iv) is punitive in character, so the person concerned must be informed of the charges and given a reasonable opportunity to meet them. An authority cannot rely on a ground not included in the notice or charge-sheet, and it must apply its mind to the material and state intelligible reasons for the conclusion reached. A vague or non-speaking order, or one founded on irrelevant or uncommunicated grounds, is arbitrary and cannot stand.
Conclusion: The removal orders were invalid and could not be sustained.
Ratio Decidendi: When statutory removal is punitive, adherence to natural justice requires prior notice of the specific charges, a meaningful opportunity to rebut them, and a reasoned order based only on relevant and disclosed grounds; a vague or non-speaking removal order is unlawful.