Court Reaffirms Locus Standi and Principles of Natural Justice in Disciplinary Proceedings
The Punjab and Haryana High Court has quashed an order issued by the Chairman of the Board of Directors of The Shahbad Cooperative Sugar Mill Limited, deeming it a violation of jurisdiction and principles of natural justice. The order, dated May 21, 2025, was challenged by Satbir Singh and another petitioner under Articles 226/227 of the Indian Constitution.
Justice Harpreet Singh Brar, presiding over the case, emphasized the importance of locus standi in service jurisprudence, reaffirming that only individuals directly affected by a legal action can challenge it in court. The court rejected the application of a whistleblower, Vineet Kumar, who sought to be impleaded as a respondent, ruling that his involvement as a complainant did not grant him the status of an aggrieved party.
The petitioners contended that the Chairman's order, which reversed the exoneration provided by the Managing Director and the Chief Vigilance Officer's inquiry reports, was arbitrary and driven by ulterior motives. They argued that the order was passed without jurisdiction, as the Chairman lacked the authority to nullify the Managing Director's orders without a collective decision by the Board of Directors.
Justice Brar highlighted that the Chairman's order was issued without providing the petitioners an opportunity to present their defense or access the complaint and materials relied upon, thus violating the principles of natural justice. The court also noted that the Chairman's action was unsupported by new evidence and disregarded the detailed findings of the Managing Director and the CVO.
The court's ruling underscores the limited scope of judicial review under Article 226, which is reserved for instances of evident perversity, irrationality, or gross irregularity in administrative decisions. The judgment mandates the restoration of the status quo prior to the impugned order, reaffirming the Managing Director's role as the principal executive officer with disciplinary control as per the Haryana Cooperative Societies Act, 1984.
The decision reinforces the judicial principle that orders must be reasoned and based on substantial evidence, adhering to the rule of law. The court's dismissal of the whistleblower's application serves as a reminder of the strict criteria for locus standi in service disputes, protecting the framework of service law from unwarranted interference.
Bottom Line:
Locus standi in service jurisprudence - Only a person directly aggrieved or suffering a legal injury can maintain an action in service disputes. Whistle blowers or complainants, despite exposing irregularities, cannot claim the status of a necessary party in disciplinary proceedings.
Statutory provision(s): Article 226, Haryana Cooperative Societies Act, 1984, Rules 31(3), 26, 27 of the Service Rules for the Employees of Cooperative Sugar Mills in Haryana
Satbir Singh v. State Of Haryana, (Punjab And Haryana) : Law Finder Doc id # 2855375
