Prospective effect limits challenge based on non-supply of inquiry report before punishment in termination proceedings.

Non-supply of the inquiry report before imposition of punishment was argued to vitiate the termination order, but the governing principle was applied prospectively. Because the relevant decision had been given prospective effect, orders passed before 29 November 1990 were not invalidated on this ground. The termination order was therefore not vitiated for non-supply of the inquiry report, and the challenge failed.

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Issues: Whether the termination order was vitiated for non-supply of the inquiry report before imposition of punishment.

Analysis: The petitioner challenged the termination order on the ground that the inquiry report had not been supplied. The Court noted the principle that non-supply of the inquiry report may render a punishment order illegal, but held that the governing decision had been given prospective effect and would not invalidate orders passed prior to 29 November 1990.

Conclusion: The termination order was not vitiated on this ground, and the petition was dismissed.

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