Prolonged suspension in departmental inquiry may be time-bound, with automatic revocation if the disciplinary process is not completed.

Prolonged suspension during pending departmental proceedings can justify judicial direction for expeditious completion of the inquiry. Where the disciplinary process remained pending for over four years, the Court noted the appointment of the Presenting Officer and the inordinate delay, then fixed a time-limit for conclusion of the proceedings and linked non-compliance to automatic revocation of suspension. The petitioner was directed to cooperate fully with the inquiry. The departmental authority was required to conclude the proceedings and pass a final order by the specified date, failing which the suspension would stand revoked.

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Issues: Whether directions were required for expeditious completion of the departmental proceedings and whether continued suspension should stand revoked if the inquiry was not concluded within the time fixed.

Analysis: The petitioner had remained under suspension for more than four years, while the departmental proceedings had not been concluded. The Court took note of the appointment of the Presenting Officer and the inordinate delay in completing the inquiry. To ensure closure of the disciplinary process, the Court fixed a time-limit for completion of the proceedings and linked non-compliance with automatic revocation of suspension. The petitioner was also directed to cooperate fully with the inquiry.

Outcome: The departmental authority was directed to conclude the proceedings by 31.03.2022, and failing completion and passing of a final order by that date, the suspension would stand revoked. The petition was disposed of accordingly.

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