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As per case facts, the Petitioner joined Haryana Police and faced an inquiry after a SIM card, registered to a deceased person in a murder case, was linked to him.
...Although the Inquiry Officer exonerated him, the Disciplinary Authority disagreed with the report, issued a show cause notice, and dismissed him. The Appellate Authority later reduced the punishment to forfeiture of three annual increments, but his revision was dismissed by the Revisionary Authority. The Petitioner then approached the High Court, challenging these Orders for alleged violation of natural justice, specifically that reasons for disagreement were not supplied, and no opportunity to represent was given before final findings were recorded. The question arose whether the Disciplinary Authority's process of disagreeing with the Inquiry Officer's report and imposing punishment, without providing specific reasons for disagreement and an opportunity to represent before recording final findings, violated principles of natural justice as established in "Punjab National Bank Vs. Kunj Behari Misra". Finally, the High Court held that the Disciplinary Authority did record reasons for disagreement in the show cause notice and granted the Petitioner an opportunity to file a reply and a personal hearing, thereby complying with principles of natural justice. The court distinguished the cited Supreme Court Judgment by noting the absence of a similar rule in the Punjab Police Rules (PPR) as found in PNB Regulations. The High Court, reaffirming its limited scope of judicial review in disciplinary matters, concluded that the authorities followed due procedure and made factual findings without any material irregularity or infirmity, thus dismissing the Petition.
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