Punjab & Haryana High Court Partly Sets Aside CAT Order; Clarifies That Minor Penalty Requires No Detailed Inquiry but Punishment Order Must Be Reasoned

Case Name: Union of India & Others vs. Central Administrative Tribunal & Another
Date of Judgment: 02 December 2025
Citation: CWP-2487-2024
Bench: Hon’ble Mr. Justice Harsimran Singh Sethi, Hon’ble Mr. Justice Vikas Suri

Held: The Punjab & Haryana High Court held that the Central Administrative Tribunal erred in directing that a detailed inquiry must be conducted even for imposing a minor penalty under Rule 16 of the CCS (CCA) Rules, 1965. The Court ruled that such direction was contrary to the statutory scheme. However, it simultaneously upheld the Tribunal’s decision to set aside the punishment because the disciplinary authority had passed a completely non-speaking order lacking reasons.

Summary: The Union of India challenged the Tribunal’s order setting aside a minor penalty imposed on respondent-employee Ved Prakash. The Tribunal had held that once allegations were denied, even for imposing a minor penalty, a detailed inquiry akin to a major penalty proceeding was necessary. The Union argued that Rule 16 of the CCS (CCA) Rules mandates only a show-cause process and consideration of the employee’s reply before passing a speaking order, and that the Tribunal had exceeded the statutory requirement.

The High Court agreed with this contention, holding that a detailed inquiry is not required for minor penalties. At the same time, the Court examined the disciplinary authority’s order and found it entirely devoid of reasoning. The order failed to indicate how the allegations relating to fraudulent entries in seven passbooks were found proved or why recovery of ₹75,000 was justified. The Court held that even in minor penalty cases, the authority must apply its mind and record reasons showing consideration of the employee’s defence, which had not been done here.

The Court therefore upheld the Tribunal’s decision to set aside the penalty, not on the ground of lack of detailed inquiry, but because the punishment order was non-speaking and violated principles of natural justice. Liberty was granted to the department to pass a fresh, reasoned order in accordance with Rule 16.

Decision: The writ petition was disposed of with a clarification: the Tribunal’s reasoning requiring a detailed inquiry for minor penalties was set aside, but the setting aside of the punishment itself was upheld. The department may issue a fresh reasoned order after considering the employee’s reply.