Supreme Court inΒ State of Punjab & Ors. vs. Ex. C. Satpal Singh (CIVIL APPEAL NO. 312 OF 2012), On August 29, 2025,Β clarified that punishment cannot be imposed based on past misconduct unless it is specifically referred to in the enquiry report or show cause notice. The Court reached this conclusion after examining the employee’s contention that the disciplinary authority had relied on his past misconduct while ordering dismissal from service, despite no such reference being made during the enquiry or in the show cause notice. It held that the dismissal was, in fact, founded on the gravest act of misconduct proved during the disciplinary proceedings, and those proceedings were conducted in accordance with prescribed procedure and principles of natural justice. Because the past misconduct was not part of the charge or enquiry, the Court found that it merely added weight to the disciplinary authority’s decision rather than forming the substantive basis of the punishment.
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