Punjab & Haryana High Court Orders State to Issue NOC to Doctor; Calls Disciplinary Action Arbitrary and Unwarranted

Case Name: Dr. Manoj vs. State of Haryana and Others
Date of Judgment: 21 November 2025
Citation: CWP-34596-2025
Bench: Hon’ble Mr. Justice Ashwani Kumar Mishra & Hon’ble Mr. Justice Rohit Kapoor

Held: The Punjab and Haryana High Court directed the State of Haryana to issue a No Objection Certificate to the petitioner, holding that denying the certificate on the basis of a pending show cause notice arising from an incident involving a public representative was arbitrary and unjustified. The Court observed that the alleged misconduct did not warrant withholding career advancement opportunities, particularly when the petitioner was on emergency duty during the COVID-19 period and had already submitted his explanation without any adverse decision being taken by the authorities.

Summary: The petitioner, serving as a Casualty Medical Officer in a government hospital in Haryana, approached the Court seeking direction for issuance of a No Objection Certificate required to pursue a Post-Graduate medical course. The NOC was denied solely on the ground that disciplinary proceedings were pending against him pursuant to a show cause notice issued after a Member of the Legislative Assembly complained that the doctor did not stand upon his arrival during the petitioner’s emergency duty in the COVID-19 period. The petitioner submitted a reply asserting that the act was unintentional and not discourteous, but the authorities did not conclude the proceedings. The State justified the withholding of the NOC due to the pendency of proceedings. The Court expressed strong disapproval of the basis of the action and observed that public representatives are expected to treat medical professionals with respect, especially those working under strain during the pandemic. The Court recorded that pursuing higher medical education involves years of effort, merit and dedication, and withholding opportunities on such grounds amounted to punitive action without cause.

Decision: The writ petition was allowed, and the State was directed to issue the No Objection Certificate to the petitioner without delay. Costs of ₹50,000 were imposed on the respondent-State, to be deposited with the Poor Patient Welfare Fund, PGIMER, Chandigarh. Pending applications were disposed of.