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Issues: Whether discharge from service on receipt of four red ink entries could be sustained without considering the nature and gravity of the misconduct, the reply to the show-cause notice, and the relevant procedural safeguards.
Analysis: The power to discharge on the basis of four or more red ink entries was held to be discretionary and not automatic. The authority was required to examine the individual case on its own merits, consider the explanation furnished by the employee, and weigh the severity of the misconduct before directing discharge. The order had to disclose application of mind to the relevant factors, because a decision based only on the numerical threshold of red ink entries would ignore the material circumstances governing the exercise of power. The Court also noted that later regulations reflected the same requirement of a case-specific enquiry, consideration of aggravating circumstances, and recording of reasons for discharge. On the facts, the discharge order did not show such consideration.
Conclusion: The discharge could not be sustained and the appellant was entitled to relief by setting aside the discharge and treating him in service for limited consequential pensionary purposes.
Ratio Decidendi: Where the governing framework confers a discretionary power to discharge on the basis of red ink entries, the authority must consider the nature and gravity of the misconduct and the individual's explanation, and must apply its mind to the relevant factors before ordering discharge; a purely numerical approach is invalid.