Prospective operation of inquiry report rule barred retrospective challenge to a prior dismissal order.

The Court reiterated that the rule in Mohd. Ramzan Khan on supplying the inquiry report before imposing punishment operated prospectively, so it could not be applied to a dismissal order made before that judgment. The High Court therefore erred in setting aside the dismissal solely on that basis without examining the other grounds raised in the writ petition. The prospective character of the earlier ruling remained intact, and reliance on it to invalidate the prior dismissal was unsustainable.

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Issues: Whether the law declared in Mohd. Ramzan Khan, relating to supply of the inquiry report before imposing punishment, could be applied retrospectively to an of dismissal passed before that decision.

Analysis: The Court held that its earlier declaration making the rule operative prospectively left no scope for the High Court to apply it to a dismissal order passed prior to that judgment. The High Court therefore erred in setting aside the dismissal on that ground without examining the remaining grounds raised in the writ petition.

Conclusion: The prospective operation of the earlier decision could not be denied, and the High Court's reliance on it was unsustainable.

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