The Rajasthan High Court, with its Jaipur Bench led by Justice Anoop Kumar Dhand, has ruled that departmental inquiries against employees should be completed within a reasonable time, preferably within six months. The court emphasized that unnecessary delays in such proceedings can cause inconvenience and harm the rights of the employees involved. It held that the responsibility of ensuring a swift conclusion of such inquiries lies with the employer.
Case Background
In this case, the petitioner was served a chargesheet on September 4, 2024, under Rule 16 of the Rajasthan Civil Services (Classification, Control, and Appeal) Rules, 1958. After responding to the charges, he found that the disciplinary inquiry was progressing very slowly. With his retirement scheduled for March 31, 2025, the petitioner approached the court, seeking a directive to speed up the inquiry so that it could be resolved before his retirement.
Court’s Observations and Ruling
The High Court referred to the Supreme Court’s judgment in Prem Nath Bali vs. Registrar, High Court of Delhi (AIR 2016 SC 101). In that case, the Supreme Court had ruled that employers must conclude departmental inquiries at the earliest, taking priority measures to complete them within a short time.
The Rajasthan High Court reiterated that when an employee is under suspension during the inquiry, it is even more critical to ensure that the process is completed promptly. A prolonged inquiry not only affects the employee’s rights but also leads to unnecessary legal complications.
Employer’s Duty to Ensure Timely Completion
The court noted that even after an inquiry is completed, adverse findings against an employee can lead to further legal proceedings, which may take additional time. Therefore, employers must prioritize and expedite inquiries to ensure that decisions are made without undue delay.
To prevent unnecessary delays, the court set an outer limit of six months for completing departmental inquiries. However, in cases where unavoidable circumstances cause delays, the employer must carefully assess the reasons and still ensure the inquiry is concluded as soon as possible.
Court’s Directive
Considering the petitioner’s impending retirement, the court directed the employer to conclude the departmental inquiry within four weeks. The ruling highlights the importance of fair and timely proceedings, ensuring that employees are not subjected to prolonged uncertainty.