Anita Agrawal vs State Of Chhattisgarh on 30 July, 2025

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Chattisgarh High Court

Anita Agrawal vs State Of Chhattisgarh on 30 July, 2025

Author: Rajani Dubey

Bench: Rajani Dubey

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                                                 Writ Petition (S) No. 2494 of 2017
                                                Anita Agrawal vs. State of Chhattisgarh




AMIT
PATEL
Digitally
signed by
AMIT PATEL



                                                                                          2025:CGHC:37294


                                                                                                       NAFR

                           HIGH COURT OF CHHATTISGARH AT BILASPUR

                                             Writ Petition (S) No. 2494 of 2017

                                               Order reserved on : 25.04. 2025
                                             Order delivered on : 30.07. 2025
                  •   Anita Agrawal W/o Prahlad Kumar Agrawal, Aged About 49 Years, Occupation
                      District Programme Officer, Women And Child Development Department, Raigarh,
                      District- Raigarh Chhattisgarh.
                                                                                                      --Petitioner
                                                                versus
                  1. State of Chhattisgarh, Through The Secretary, Women And Child Development
                      Department, Mahanadi Bhawan, Mantralaya, New Raipur, District Raipur
                      Chhattisgarh.
                  2. Under Secretary, State of Chhattisgarh, Women And Child Development Department,
                      Mahanadi Bhawan, Mantralaya, New Raipur, District Raipur Chhattisgarh., District :
                      Raipur, Chhattisgarh
                  3. Collector, Raigarh, District Raigarh Chhattisgarh., District : Raigarh, Chhattisgarh
                                                                                                   --Respondents
                      For Petitioner         : Ms. Hamida Siddiqui, Advocate.
                      For State              : Ms. Nandkumari Kashyap, Panel Lawyer
                                       Hon'ble Smt. Justice Rajani Dubey

                                                       C A V ORDER

1. The petitioner has filed this petition under Article 226 of the Constitution of

India by challenging the legality, validity and propriety of the order dated

17.04.2017 (Annexure P/1) passed by respondent No. 2, by which the penalty

has already been decided by the department against the provision of
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Writ Petition (S) No. 2494 of 2017
Anita Agrawal vs. State of Chhattisgarh

Chhattisgarh Civil Services (Classification, Control and Appeal) Act, 1966

without issuing show cause notice upon the proposed punishment. So, this

petition is sought by the petitioner for the following reliefs:-

“10.1. That this Hon’ble Court may kindly be pleased to quash/set-aside
the impugned order dated 17-04-2017 (Annexure P-1) as well as the entire
proceeding of the departmental enquiry initiated by the respondent
authorities.

10.2. That the Hon’ble Court be further pleased to grant such other relief(s)
as may be deemed fit and proper in the interest of justice and fair play.”

2. The facts of the case, as projected in the present writ petition, in brief, there

was tender for purchasing of pre-school kits for the year 2012-13 and the

committee was constituted, whose head was the Collector, whereas the charge

to the effect has been leveled against her that the petitioner being a member as

a Secretary of the purchase committee did not purchase the pre-school kits

from the lowest bidder. A decision was taken by respondent No. 2 to constitute

a departmental enquiry against the petitioner and notice dated 08.10.2015 was

issued along with the charge-sheet and other relevant documents to the

petitioner. After receiving the said notice, on 23.10.2015 the petitioner seeking

time for submitting reply of the said notice upon the departmental enquiry.

After reminder notice dated 07.11.2015 issued by respondent No. 2, the

petitioner had replied to the the reminder notice on 16.11.2015, copy of which

are collectively filed as Annexure P/4. The department was not satisfied with

the reply of petitioner and therefore, D.E. instituted against the petitioner and

evidence of witnesses have been recorded between 20.07.2016 to 04.08.2016.

It has been further contended that the Presenting Officer below the rank of the

petitioner has been appointed and the said officer has given brief of the matter

to the petitioner. After this brief, petitioner has made reply to the department

on 21.12.2016, in which the main contention of the petitioner was that in the
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Anita Agrawal vs. State of Chhattisgarh

entire proceedings for the purchase of pre-school kits, she was alone not

responsible. Thereafter, the impugned order/notice dated 17.04.2017

(Annexure P/1) issued by respondent No. 2 to the petitioner, however, the

petitioner has given the reply of the said impugned order on 20.04.2017,

wherein it was mentioned that as per the provision of the Act, 1966 if the

Enquiry Officer has made any opinion about the charges leveled against the

delinquent employee and evidence laid by the parties, will send this opinion

and prima facie holding the guilt of the delinquent employee to the

disciplinary authority. Disciplinary authority, thereafter going through the

opinion of the enquiry officer will issue a show cause notice to the delinquent

employee, so as to why not the proposed penalty be imposed upon him or her,

but after the issuance of brief of departmental enquiry, there is no

communication to the petitioner and suddenly the impugned notice has been

served upon the petitioner, which in fact is imposition of penalty, which is bad

in law. Hence, this present petition.

3. Learned counsel for the petitioner submits that the impugned order/notice

dated 17.04.2017 (Annexure P/1) is illegal, arbitrary, improper and incorrect,

hence it is liable to be set aside, the impugned order and procedure applied by

the respondent authorities is against the Chhattisgarh Civil Services

(Classification, Control, and Appeal) Rules, 1966 (often referred to as the CCS

(CCA) Rules, 1966), particularly, against the Rule 45 of the Act, 1966, the

method adopted by the respondents is against the Memo No. C-26/92/3/1

dated 20.08.1992 and against the settled provisions of Rule 14 (23), 15 (1), 15

(3) of the Act, 1966 as well as the principles of natural justice. The impugned

order dated 17.04.2017 shows the prejudice mind of the respondent authorities

for not constituting the D.E. against other members of the Committee as well
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Writ Petition (S) No. 2494 of 2017
Anita Agrawal vs. State of Chhattisgarh

as deciding the punishment without going through report of enquiry officer. As

per the provision of the Act, 1966, if the enquiry officer has made any opinion

about the charges leveled against the delinquent employee and evidence laid

by the parties, will send this opinion and prima facie holding the guilt of the

delinquent employee to the disciplinary authority. Thereafter, after going

thorough the opinion of the enquiry officer will issue a show cause notice to

the delinquent employee, so as why not the proposed penalty be imposed upon

him or her, but after the issuance of brief of departmental enquiry, there is no

communication to the petitioner and suddenly the impugned notice has been

served upon the petitioner, which in fact is imposition of penalty, which is bad

in law, so the impugned order is liable to be set aside. Referring to the

decision of Hon’ble Apex Court in the matter of The State of Uttar Pradesh

and Ors. vs. Rajit Singh1 & in the matter of Union of India vs. E. Bashyan2

4. On the contrary, learned counsel for respondents No. 1 to 3/State strongly and

vehemently opposes the above prayer made by learned counsel for the

petitioner and submits that while the petitioner was posted as District

Programme Officer, WCD, Korba, the petitioner had committed illegality in

purchasing the pre- school kits from the highest bidder, which was against the

rules and on account of the act of the petitioner, the public exchequer cause a

financial loss. A charge-sheet along with the list of documents and list of

witnesses vide Annexure P/2 was served upon the petitioner leveling a single

charge and the petitioner has replied the same. She further submits that being

dissatisfied with the reply submitted by the petitioner, the department has

decided to institute a departmental enquiry against the petitioner by appointing

the Enquiry Officer being Additional Collector, Korba and presenting Officer

1. (2022) 15 SCC 254

2. 1988 AIR 1000
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Writ Petition (S) No. 2494 of 2017
Anita Agrawal vs. State of Chhattisgarh

being District Programme Officer, WCD, Korba. The Enquiry Officer after

following due process of law and after affording due opportunity of hearing,

has conducted the departmental enquiry, in which the charge leveled against

the petitioner has been found to be proved. Thereafter, a report dated

31.12.2016 has been submitted by the Enquiry Officer as Annexure R-1. After

receipt of the Enquiry Officer, a tentative decision of the disciplinary authority

has been given to the petitioner by way of the impugned notice (Annexure

P/1) and hence, the principles of natural justice have been fully complied with

by the respondents. The impugned notice is not a final order of punishment,

whereas the same is a notice in order to comply with the principles of natural

justice to the petitioner before taking any final decision in the case of the

petitioner. Hence, the entire petition is devoid of merit and substance and

accordingly is liable to be dismissed at the threshold in the light of the

judgment passed by Hon’ble Apex Court in the matter of Punjab National

Bank Vs. Kunj Behari Misra3 and in the matter of Yoginath D. Bagde vs.

State of Maharashtra.4

5. Heard learned counsel for the respective parties and perused the material

available on record.

6. It is an admitted position in this case that petitioner was working as District

Programme Officer and a charge-sheet was issued against her and

departmental enquiry instituted against the petitioner and after completing the

departmental enquiry, the disciplinary authority issued impugned notice as

Annexure P/1 to the petitioner.

7. The main objection of the petitioner is that the said notice is against the CCA

Rules, 1966 and principles of natural justice.

3 (1998) 7 SCC 84
4 (1999) 7 SCC 739
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8. Learned counsel for the petitioner submits that in the entire proceedings for

purchasing of pre-school kits in the year 2012-13, petitioner alone was not

responsible, as one committee was constituted for purchasing, in which the

Collector was the main head and apart from the petitioner there were three

other members in that said committee who are 1. District Manager,

Department of Commerce and Industry, 2. Principal of I.T.I, Korba, 3.

Principal, Aanganbadi Training Centre, Korba and final decision was taken by

the committee anonymously and this decision of the committee was

recommended by the Collector, therefore, she alone cannot be held responsible

and the entire proceedings drawn against her is mala fide and she has been

made scapegoat.

9. Petitioner has filed a copy of charge-sheet and other documents, whereas the

respondents/State has filed a enquiry report vide Annexure R-1. In this enquiry

report also, it is evident that a purchase Committee was constituted, in which

five members of the said Committee, the said Committee headed by the

Collector with other four members.

10. For the sake of convenience, the enquiry report is reproduced hereinbelow for

ready reference :-

” …….प्रदर्शित अभिलेखों का विवरण दिया गया है। प्रदर्श पी-4 टीप पत्र
दिनांक 29.01.2013 के अनुसार वित्त वर्ष 2012-13 में प्री-स्कूल किट क्रय हेतु निम्नानुसार क्रय
समिति का गठन किया गया है:-

(1) कलेक्टर द्वारा नामांकित प्रतिनिधि – श्रीमती इफ्फतआरा
(तत्कालीन अपर कलेक्टर कोरबा),

(2) जिला कार्यकम अधिकारी
महिला एवं बाल विकास विभाग कोरबा – सचिव
(3) जिला प्रबंधक
व्यापार एवं उद्यद्योग विभाग – सदस्य
(4) प्राचार्य आई टी आई कोरबा – सदस्य
(5) प्राचार्य शासकीय आं गनबाड़ी
प्रशिक्षण केन्द्र कोरबा – सदस्य

उक्त क्रय समिति में वित्तीय मामलों के जानकार अधिकारी रखा जाना
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Writ Petition (S) No. 2494 of 2017
Anita Agrawal vs. State of Chhattisgarh

आवश्यक था, जो पारार्मश दे सके, किन्तु उन्हे क्रय समिति में नहीं रखा गया और
ना ही उन्हें क्रय समिति में रखें जाने हेतु अपचारी सेवक ने तत्कालीन कलेक्टर
महोदय से अनुमोदन लिया है। “

11. It was found by the Enquiry Officer in enquiry report, which is reproduced

hereinbelow for ready reference :-

” चूंकि शासन द्वारा प्री स्कूल किट क्रय, हेतु वर्षवार आबंटन जारी किया जाता है, अतः अपचारी सेवक

एवं उनके बचाव साक्षियों का कथन कि गुणवत्ता को देखते हुये न्यूनतम निविदा दर से अधिक दर वाले

निविदाकार की निविदा स्वीकृत की गई है, कोई मायने नहीं रखता है। अतः अपचारी सेवक पर लगाये

गये आरोप क्रमांक -1: विभागीय जांच में सही पाये जाते हैं।

( घ) प्रत्येक आरोप पद पर निष्कर्ष और उनके कारण:–

मेरे समक्ष प्रस्तुत दस्तावेजों एवं कथनों के आधार पर तथा उपरोक्त वर्णित कारणों के प्रकाश

में मैं श्रीमती अनिता अग्रवाल तत्कालीन जिला कार्यक्रम अधिकारी महिला एवं बाल विकास विभाग

कोरबा के विरुद्ध लगाये गये आरोप को पूर्ण तः प्रमाणित पाता हू।ं ”

12. It is evident from the inquiry report that the Enquiry Officer did not mention

in his report that how the petitioner is alone responsible for purchasing the

pre-school kits order, though, it is an admitted position that Additional

Collector and other persons are also the members of the said Committee and

after that Collector herself, being the head of the committee has recommended

for the order of purchase of the said articles.

13. Enquiry Officer has also held that “…..यदि यह भी मान लिया जाए कि उच्च गुणवत्ता वाली
सामाग्री को खरीदा गया तो मोल भाव की संभावना हमेशा रहती है। क्रय समिति का कार्य यह देखना है कि क्रय

प्रकिया में भण्डार क्रय नियम का पालन हो, उच्च गुणवत्ता सामाग्री की आपूर्ति हो तथा शासकीय धन की बचत

हो । यद्यपि यह कहना सही हो सकता है कि एक ही प्रकार की सामाग्री के क्रय मूल्य गुणवत्ता के आधार पर

अलग-अलग हो सकता है किन्तु उच्च गुणवत्ता कि सामाग्री को मोल भाव अधिक भुगतान से बचा जा सकता था।

यद्यपि श्रीमती अनीता अग्रवाल द्वारा यह तर्क दिया गया है कि प्री स्कूल किट क्रय समिति द्वारा कि गई है अतः

वे इसके लिए अकेले जिम्मेदार नहीं हैं किन्तु समिति के सचिव होने के कारण जिला कार्यकम अधिकारी का

उत्तरदायित्व बनता है।… ”

14. It has been held by the Hon’ble Apex Court in the matter of The State of Uttar

Pradesh (supra) in para 09, which reads as under:-

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Writ Petition (S) No. 2494 of 2017
Anita Agrawal vs. State of Chhattisgarh

“9. From the impugned judgment and order passed by the High
Court, it appears that when the aforesaid submission and the
aforesaid decision was pressed into service, the High Court has
not considered the same on the ground that the other officers
involved in respect of the same incident are exonerated and/or no
action is taken against them. Applying the law laid down in the
case of A. Masilamani (supra) to the facts of the case on hand, we
are of the opinion that the Tribunal as well as the High Court
ought to have remanded the matter to the Disciplinary Authority
to conduct the enquiry from the stage it stood vitiated. Therefore,
the order passed by the High Court in not allowing further
proceedings from the stage it stood vitiated, i.e., after the
issuance of the charge sheet, is unsustainable.:”

15. It is also evident from the documents filed by both the parties that after

enquiry report, impugned order/notice (Annexure P/1) issued against the

petitioner by respondent No. 2. Thereafter, on 20.04.2017, the petitioner

replied of the same as Annexure P/8, wherein she raised the objection on this

ground that before taking any decision, no show cause notice was issued as

per Rule 14 (23) of CCA Rule.

16. Learned counsel for the respondent/State submits that Annexure P/1 is a notice

as per Rule 14 (23) of CCA Rule, but it is evident from Annexure P/1 that it is

not a show cause notice, but it is only notice regarding the imposition of

penalty.

17. Operative para of Annexure P/1 is reproduced hereinbelow for ready

reference:-

” विषयान्तर्गत आपके विरुद्ध लंबित लोक आयोग जांच प्रकरण क्रमांक 74/2015 म जांच में आरोप
पूर्ण त्तः प्रमाणित पाये जाने के कारण छ०ग० सिविल सेवा (वर्गीकरण नियंत्रण तथा अपील) नियम
1966 के नियम 10 के अन्तर्गत उल्लेखित शास्तियों में से दीर्घ शास्ति दिए जाने का अन्तिम
(प्रावधिक) निर्णय लेते हुए पदानवत किये जाने का निर्णय लिया गया है। तदनुसार समक्ष में सुनवाई
हेतु दिनाक 22.04.2017 की अपरान्ह 12:00 बजे सचिव महिला एवं जल विकास विभाग मंत्रालय के
भूतल स्थित कक्ष क्रमांक -एस-0-10 में उपस्थित होना सुनिश्चित करे”

18. For the sake of convenience, it would be appropriate to quote Rule 14 (23) of

Chhattisgarh Civil Services (Classification, Control and Appeal) Act, 1966:-

14. Procedure for imposing major penalties.

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Anita Agrawal vs. State of Chhattisgarh

(23) (i) After the conclusion of the inquiry, a report shall be prepared

and it shall contain-

(a) the articles of charge and the statement of the imputations of
misconduct or misbehaviour;

(b) the defence of the Government servant in respect of each ~
article of charge;

(c) an assessment of the evidence in respect of each article of
charge;

(d) the findings on each article of charge and the reasons
therefor.

EXPLANATION- If in the opinion of the inquiring authority the proceedings
of the inquiry establish any article of charge different from the original articles
of the charge, it may record its findings on such article of charge:

Provided that the findings on such article of charge shall not be recorded
unless the Government servant has either admitted the facts on which such
article of charge is based or has had a reasonable opportunity of defending
himself against such article of charge.

(ii) The inquiring authority, where it is not itself the disciplinary
authority, shall forward to the disciplinary authority the records of
inquiry which shall include :-

(a) the report prepared by it under clause (i);

(b) the written statement of defence, if any, submitted by the
Government servant;

(c) the oral and documentary evidence produced in the course of
the inquiry;

(d) written briefs, if any, filed by the Presenting Officer or the
Government servant or both during the course of the inquiry; and

(e) the orders, if any, made by the disciplinary authority and the
inquiring authority in regard to the inquiry.

19. It has been held by the Hon’ble Apex Court in the matter of the Union of

India (supra) in para 04, which reads as under:-

” It is no doubt true that when the Constitution Bench
rendered the aforesaid decision in H.C. Goel’s case Article
311(2)
had not yet been amended. However, that makes little
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Anita Agrawal vs. State of Chhattisgarh

difference. By virtue of the amendment what has been
dispensed with is merely the notice in the context of the
measure of penalty proposed to be imposed. 1 he opportunity
required to be given to a delinquent which must be reasonable
opportunity compatible with principles of Natural Justice has
not been dispensed with by virtue of the said amendment.
Therefore the view taken in the context of the contention that
the Discipli- nary Authority need not afford an opportunity to
the delinquent in regard to the measure of the punishment will
not hold good in the context of the present argument in the
background of the non-supply of the report of the Enquiry
officer. In the event of the failure to furnish the report of the
Enquiry officer the delinquent is deprived of crucial and
critical material which is taken into account by the real
authority who holds him guilty namely, the Disciplinary
Authority. He is the real authority because the Enquiry officer
does no more than act as a delegate and furnishes the relevant
material including his own assessment regarding the guilt to
assist the Disciplinary Authority who alone records the
effective finding in the sense that the findings recorded by the
Enquiry officer standing by themselves are lacking in force
and effectiveness. Non-supply of the report would therefore
constitute violation of principles of Natural Justice and
accordingly will be tantamount to denial of reasonable
opportunity within the meaning of Article 311(2) of the
Constitution.”

20. It has been held by the Hon’ble Apex Court in the matter of the State of Uttar

Pradesh vs. Ram Prakash Singh5 in paras 28 & 34, which read as under:-

28. The majority opinion in the Constitution Bench decision of B. Karunakar

(supra) was authored by Hon’ble P.B.Sawant, J. The questions which this Court

considered are as under:

“2. The basic question of law which arises in these matters is whether the report of
the enquiry officer/authority who/which is appointed by the disciplinary authority
to hold an enquiry into the charges against the delinquent employee, is required to
be furnished to the employee to enable him to make proper representation to the

5 2025 SCC OnLine SC 891
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Anita Agrawal vs. State of Chhattisgarh

disciplinary authority before such authority arrives at its own finding with regard to
the guilt or otherwise of the employee and the punishment, if any, to be awarded to
him. This question in turn gives rise to the following incidental questions:

i. Whether the report should be furnished to the employee even when the statutory
rules laying down the procedure for holding the disciplinary enquiry are silent on
the subject or are against it?

ii. Whether the report of the enquiry officer is required to be furnished to the
delinquent employee even when the punishment imposed is other than the major
punishment of dismissal, removal or reduction in rank?

iii. Whether the obligation to furnish the report is only when the employee asks for
the same or whether it exists even otherwise?

iv. Whether the law laid down in Mohd. Ramzan Khan case will apply to all
establishments — Government and non- Government, public and private sector
undertakings?

v. What is the effect of the non-furnishing of the report on the order of punishment
and what relief should be granted to the employee in such cases?

vi. From what date the law requiring furnishing of the report, should come into
operation?

vii. Since the decision in Mohd. Ramzan Khan case has made the law laid down
there prospective in operation, i.e., applicable to the orders of punishment passed
after November 20, 1990 on which day the said decision was delivered, this
question in turn also raises another question, viz., what was the law prevailing prior
to November 20, 1990?” (emphasis ours)

34. Hon’ble Ramaswamy, J. answered the basic question as follows:

“61. It is now settled law that the proceedings must be just,
fair and reasonable and negation thereof offends Articles 14
and 21. It is well-settled law that the principles of natural
justice are integral part of Article 14. No decision prejudicial
to a party should be taken without affording an opportunity or
supplying the material which is the basis for the decision. The
enquiry report constitutes fresh material which has great
persuasive force or effect on the mind of the disciplinary
authority. The supply of the report along with the final order is
like a post-mortem certificate with putrefying odour. The
failure to supply copy thereof to the delinquent would be
unfair procedure offending not only Articles 14, 21 and 311(2)
of the Constitution, but also, the principles of natural justice.
The contention on behalf of the Government/management that
the report is not evidence adduced during such enquiry
envisaged under proviso to Article 311(2) is also devoid of
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Anita Agrawal vs. State of Chhattisgarh

substance. It is settled law that the Evidence Act has no
application to the enquiry conducted during the disciplinary
proceedings. The evidence adduced is not in strict conformity
with the Indian Evidence Act, though the essential principles
of fair play envisaged in the Evidence Act are applicable.
What was meant by ‘evidence’ in the proviso to Article 311(2)
is the totality of the material collected during the enquiry
including the report of the enquiry officer forming part of that
material. Therefore, when reliance is sought to be placed by
the disciplinary authority, on the report of the enquiry officer
for proof of the charge or for imposition of the penalty, then it
is incumbent that the copy thereof should be supplied before
reaching any conclusion either on proof of the charge or the
nature of the penalty to be imposed on the proved charge or on
both.” (emphasis ours)

21. In the light of the aforesaid discussion and in the light of the above judgments,

it is also evident that after the enquiry report (Annexure R/1), no show cause

notice appears to have been issued to the petitioner and impugned order/notice

(Annexure P/1) clearly shows that the decision was taken by the disciplinary

authority for demotion of the petitioner and this is a clear violation of service

rules and principles of natural justice.

22. It is also quite evident that respondents/State has failed to submit this fact that

what action was taken against the other members of the purchasing committee

except the petitioner. It is quite evident from enquiry report that regarding

purchase of the said articles, a joint decision was taken by the said committee

comprising of five members, in which the Additional Collector was one of the

member and also President of this Committee, but disciplinary action was only

taken against the petitioner by excluding the other members. Further, it is also

not evident from the reply and documents filed by the respondents that in the
13
Writ Petition (S) No. 2494 of 2017
Anita Agrawal vs. State of Chhattisgarh

said committee, Additional Collector was the President and the petitioner was

the Secretary and the rest three members are also in the said Committee and

in enquiry report, the Enquiry Officer also found that purchasing committee

has followed the rule of the Chhattisgarh State Stores Purchase Rules, 2002

(Bhandar Kray Niyam 2002) and trying to save money of the government and

the petitioner was the Secretary of the said committee, so she alone is

responsible for all this misconduct, this finding is also against the principles of

natural justice and service rules.

23. Petitioner filed various note-sheets which shows that all decision taken by the

purchasing committee and it is evident that the concerned Collector issued

purchasing order. It is also admitted by the respondent that during the

disciplinary enquiry, Presenting Officer was below the rank of the petitioner

which is also not according to the service rules.

24. As such looking to the facts and circumstance of the case, the instant petition

is allowed and the impugned order/notice dated 17.04.2017 (Annexure P/1)

and entire proceedings of departmental enquiry are hereby quashed/set aside

with all consequential benefits. However, liberty is granted to the disciplinary

authority to initiate a fresh departmental enquiry against the petitioner, if so

desire and after affording reasonable opportunity of hearing/defence to the

petitioner, pass a fresh appropriate order as per service rules and also adhering

to the principles of natural justice.

25. As an upshot, the writ petition stands allowed to the above extent.

Sd/-

(Rajani Dubey)
JUDGE
AMIT PATEL

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