The Court overturned a disciplinary penalty imposed on Dr. Subash Thakur, an anesthetist at Civil Hospital, Rampur, in Shimla, after concluding that the departmental inquiry report against him was vague and inconclusive. While the inquiry suggested that Dr. Thakur may have assisted in surgery at a private clinic—a breach of his non-practice allowance—the report used speculative language like “possibility” of involvement, without firmly establishing guilt. Based on two nurses’ statements, the disciplinary authority docked his pay and froze increments for three years. But the High Court held that such an inconclusive finding “cannot be treated as an inquiry establishing the proof of guilt … even on testing the same, degree of proof required to prove charge in Departmental Inquiry/service jurisprudence” . Since the inquiry report did not conclusively prove any charge, it could not form a valid basis for penalty.

This ruling reinforces the legal principle—grounded in Supreme Court precedents—that disciplinary proceedings must rely on specific, cogent, and legally admissible findings, not conjecture or ambiguity. Vague allegations undermine the principles of natural justice and exceed the limited scope of judicial review .

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