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    <title>1987 (4) TMI 482 - Supreme Court</title>
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    <description>Under the confidential reports framework, the reporting authority for an Inspector General of Police had to be an officer superior in rank, and the statutory police hierarchy could not be displaced by business allocation rules under Article 166. The Home Secretary therefore could not validly act as the reporting authority, and the report prepared by him was liable to be quashed. The rules on completion, review, acceptance and communication of adverse remarks were directory, but they still required substantial compliance. Communication of adverse remarks after twenty-seven months was held to defeat the object of timely correction and was treated as vitiating the remarks.</description>
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