Suspension in corruption cases does not lapse automatically for want of a charge-sheet within three months.

Suspension in service matters does not lapse automatically merely because no charge-sheet or charge memo is filed within three months, where the governing service rules do not create such a consequence. The three-month reference drawn from Section 167(2) CrPC applies to criminal custody and cannot be treated as a general rule for service discipline. In a case involving grave corruption allegations, a red-handed bribe interception, and pending proceedings under the Prevention of Corruption Act, suspension must be assessed on the facts, the seriousness of the charge, the applicable service rules, and public interest. Judicial review is limited, and the writ court's interference with the suspension was unsustainable.

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Issues: Whether an order of suspension could be set aside merely because no charge-sheet or charge memo was filed within three months, and whether such suspension could be interfered with in a case involving serious corruption charges.

Analysis: The governing service regulations did not provide for automatic revocation of suspension on expiry of three months. The three-month reference in the relied-upon precedent was traced to the criminal procedure context under Section 167(2) of the Code of Criminal Procedure, 1973, and was held not to create a general rule for service matters. In a case where the employee was caught red-handed accepting bribe and criminal proceedings under the Prevention of Corruption Act, 1988 were pending, the Court held that suspension has to be assessed on the facts, the gravity of the allegations, the applicable service rules, and public interest. Judicial review in such matters is limited, and suspension is not to be revoked mechanically on the ground of delay alone.

Conclusion: The suspension order was not liable to be set aside on the ground that no charge-sheet was filed within three months, and interference with the suspension by the writ court was unsustainable.

Final Conclusion: The appeal succeeded and the judgment setting aside the suspension was reversed, while directions were issued to expedite the criminal proceedings and permit a representation if the matter remained pending beyond a reasonable time.

Ratio Decidendi: In cases involving grave corruption allegations and pending criminal proceedings, suspension does not lapse automatically for want of a charge-sheet within three months, and the validity of suspension must be tested under the applicable service rules on the facts of the case.

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