Natural justice in service termination requires disclosure of the inquiry report and a fair hearing before adverse action.

An adverse administrative action affecting service rights cannot be sustained on the basis of a fact-finding report unless the affected persons are supplied the material and given notice and a fair opportunity to respond before the final decision. Because the appellants were not furnished the inquiry report and were denied pre-decisional hearing, the cancellation of their placement and consequential termination breached natural justice and was invalid. The alleged illegality in placement also could not justify termination where the record did not show fraud, undue influence, or manipulation by the appellants, and the statutory scheme could not be applied on the basis of a one-sided inquiry.

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Issues: (i) Whether the cancellation of the appellants' placement and termination of service could be sustained without supplying the inquiry report and without giving notice and an opportunity of hearing. (ii) Whether the alleged illegality in placement could be used to uphold the termination despite the absence of any direct involvement by the appellants and the statutory scheme governing placement and appointment.

Issue (i): Whether the cancellation of the appellants' placement and termination of service could be sustained without supplying the inquiry report and without giving notice and an opportunity of hearing.

Analysis: The action was founded on a fact-finding report and led to termination of services on the assumption that the placements were illegal. The appellants were not furnished the report and were not given any pre-decisional notice or hearing. Since the decision carried civil consequences, the minimum requirement of fair procedure applied. A person affected by an adverse administrative decision must be informed of the material against him and afforded an opportunity to controvert it before a final decision is taken.

Conclusion: The cancellation and consequential termination were invalid for breach of natural justice and were liable to be quashed.

Issue (ii): Whether the alleged illegality in placement could be used to uphold the termination despite the absence of any direct involvement by the appellants and the statutory scheme governing placement and appointment.

Analysis: The record did not establish that the appellants had procured their placements by fraud, undue influence, or manipulation. The Court treated the broad condemnation of the placements as unjustified where the statutory validity of the appointments could not be finally determined against the appellants without hearing them. The statutory framework could not be invoked to deny relief on the basis of a one-sided inquiry, and the High Court's reliance on cases involving clearly illegal appointments was held to be misplaced on the facts.

Conclusion: The alleged illegality in placement did not justify sustaining the termination against the appellants.

Final Conclusion: The appeals succeeded, the impugned orders were set aside, and the appellants were directed to be treated as continuing in service, with the stated protections regarding disciplinary proceedings and lawful relocation.

Ratio Decidendi: Where an adverse administrative action affecting civil rights is founded on an inquiry report, the affected persons must be supplied the material and given a fair opportunity of hearing before the action is taken; otherwise the decision is a nullity.

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