ISSUE:
Whether the dismissal of the employee without holding an inquiry was justified under the circumstances?
Whether the employer’s decision to dispense with the inquiry was subject to judicial review?
Whether the plea of ‘loss of confidence’ by the employer was a valid ground for dismissal?
RULE:
Dispensing with an Inquiry: The disciplinary authority can dispense with an inquiry only if it records reasons demonstrating that holding an inquiry is "not reasonably practicable." A mere assertion is insufficient; there must be tangible material indicating that an inquiry would be obstructed by threats, coercion, or non-cooperation of witnesses.
Judicial Review of Administrative Discretion: Courts do not act as appellate authorities over administrative decisions but may intervene if the decision is vitiated by "illegality, irrationality, or procedural impropriety." The focus is on whether there was a reasonable basis for dispensing with the inquiry, not whether the court would have arrived at a different conclusion.
Loss of Confidence Doctrine: When misconduct affects an employer’s "faith in the integrity and reliability" of an employee, particularly in a public-facing role, dismissal can be justified even without an inquiry. Courts will not force reinstatement where continued employment is "detrimental to discipline and operational efficiency."