(Delhi): In a significant ruling reinforcing the principles of natural justice, the Supreme Court has held that a disciplinary authority cannot punish an employee on a charge that was never originally framed unless a fresh show-cause notice is issued and an opportunity to respond is granted.
The judgment came in the case of Dr. Nigam Prakash Narain vs. National Medical Commission & Ors., decided by a Bench comprising Justices Dipankar Datta and Satish Chandra Sharma.
The case involved a 76-year-old pediatrician who was initially accused of appearing simultaneously for inspections of two medical colleges. The doctor successfully defended himself by establishing that he was abroad during one of the inspections. However, the disciplinary authority later shifted the basis of punishment to an alleged “mis-declaration” and suppression of prior employment details — a charge that was never part of the original proceedings.
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The Supreme Court observed that once the original charge had been successfully rebutted, authorities could not impose punishment on an altogether different allegation without issuing a fresh notice. The Court held that such action amounted to denial of fair hearing and violated settled principles of natural justice.
Relying on its earlier ruling in Ravi Oraon vs. State of Jharkhand, the Bench reiterated that disciplinary proceedings must remain confined to the charges originally framed unless the delinquent employee is informed of any new allegations and given a reasonable opportunity to defend them.
The Court observed that the Executive Committee of the medical regulator committed a “serious flaw” by punishing without a fresh show-cause notice. While acknowledging the importance of maintaining integrity in medical education inspections, the Bench emphasised that procedural fairness cannot be sacrificed.
