Stigmatic Termination of Contractual Employee Sustainable if Principles of Natural Justice Are Followed: Punjab & Haryana High Court Upholds HKRNL Employee’s Dismissal After Inquiry and Show Cause Notice
Case Name: Vipin Yadav v. State of Haryana & Others
Date of Judgment: 21 July 2026
Citation: CWP-21562-2026
Bench: Hon’ble Mr. Justice Harpreet Singh Brar
Held: The Punjab and Haryana High Court upheld the termination of an HKRNL contractual employee accused of involvement in alleged examination result manipulation, holding that although a stigmatic termination founded on allegations of misconduct must comply with the principles of natural justice even in the case of contractual employees, a full-fledged departmental inquiry is not indispensable where the employee has been afforded an effective opportunity of hearing. Since the petitioner had participated in the inquiry conducted by the University, his statement had been recorded, and he was thereafter issued a show cause notice by HKRNL to which he submitted a detailed reply before termination, the requirements of natural justice stood satisfied. However, the Court directed the University to consider the petitioner’s claim for unpaid salary for the period preceding his termination.
Summary: The petitioner was initially engaged as a Lab Attendant through an outsourcing agency and was subsequently deployed through the Haryana Kaushal Rozgar Nigam Limited (HKRNL). His services were terminated following allegations relating to the alleged fraudulent updation of students’ examination results. The petitioner contended that he merely forwarded an application received from a student, had no authority or technical access to alter examination results, and that the termination order was stigmatic as it was founded upon allegations of fraud, forgery and criminal conspiracy. He argued that such a termination could not be sustained without a regular departmental inquiry and relied upon judicial precedents concerning stigmatic termination.
The respondents submitted that the petitioner was a contractual employee governed by the terms of his deployment under HKRNL. They pointed out that an Inquiry Committee constituted by the University had examined the matter, recorded the petitioner’s statement, and submitted its report. Based on that material, HKRNL issued a detailed show cause notice, considered the petitioner’s written reply, and thereafter terminated his deployment on account of loss of trust arising from the allegations. The respondents further argued that contractual employees are not governed by Article 311 of the Constitution or statutory service rules applicable to regular government servants.
The High Court reaffirmed that even contractual employees are entitled to observance of the principles of natural justice where termination is founded upon allegations of misconduct carrying a stigma, relying upon the Supreme Court’s decision in U.P. State Road Transport Corporation v. Brijesh Kumar. However, the Court distinguished between the entitlement to natural justice and the adequacy of compliance in a given case. It found that the petitioner had been afforded two independent opportunities to defend himself—first before the University’s Inquiry Committee and thereafter through a show cause notice issued by HKRNL, to which he submitted a detailed explanation. Since the explanation was considered before passing the termination order, the Court held that the procedural requirements of natural justice had been duly complied with and declined to interfere with the termination. Nevertheless, as the petitioner’s salary had allegedly remained unpaid for the period prior to termination, the Court directed the University to examine his claim by passing a reasoned order within two months and release any amount found payable in accordance with law.
Decision: The Punjab and Haryana High Court declined to interfere with the petitioner’s termination, holding that the stigmatic termination was preceded by adequate compliance with the principles of natural justice through an inquiry and a subsequent show cause notice. The writ petition was disposed of with a direction to the University to decide the petitioner’s claim for unpaid salary for the period preceding termination by passing a reasoned order within two months and to release any admissible dues.