Md. Naushad Alam v. The State Of Bihar
IN THE HIGH COURT OF JUDICATURE AT PATNA
Civil Writ Jurisdiction Case No.3750 of 2023 ====================================================== Md. Naushad Alam Son of Abdul Gaffar Resident of Village-Marhiya, P.O.- Lauriya, P.S. Lauriya, Dist.-West Champaran, At Present Posted as SubInspector of Police at Hajipur Town Police Station Hajipur, Dist.-Vaishali. ... ... Petitioner/s
Versus
1.
The State of Bihar through the Principal Secretary, Dept. of Home and Affairs, Bihar, Patna.
2.
The Director General of Police, Bihar Patna.
3.
The Deputy Inspector General of Police (Welfare) Bihar Police Head Quarter, Bihar at Patna.
4.
The Inspector General of Police, Tirhut Devision at Muzaffarpur. 5.
The Superintendent of Police, Vaishali at Hajipur. 6.
The Sub-Divisional Prosecuting Officer, Hajipur at Hajipur. 7.
The Sub-Divisional Prosecuting Officer, Mahua, Dist.-Vaishali. ... ... Respondent/s ====================================================== Appearance :
For the Petitioner/s :
Mr. Siddharth Harsh, Advocate :
Mr. Shivanand Singh, Advocate :
Mr. Andili Ambrose, Advocate :
Ms. Amisha Pranash, Advocate For the Respondent/s :
Mr. P.K. Verma, AAG-3 :
Mr. Suman Kumar Jha, AC to AAG-3 :
Ms. Rupali Jha, Advocate ====================================================== CORAM: HONOURABLE MR. JUSTICE RITESH KUMAR ORAL JUDGMENT Date : 12-02-2026 Heard the parties.
2. The present writ petition has been filed for the following reliefs:- I. For quashing the order contained in Memo no. 3690 dated 1.10.2022 passed by the Inspector General of Police Tirhut Division, Muzaffarpur
2/25 whereby and where under the appeal of the petitioner was dismissed and order of punishment contained in Memo no. 1833 dated 28.4.2022 passed by the Superintendent of police Vaishali at Hajipur in departmental proceeding no. 67/21 has been affirmed.
II. For quashing the order contained in Memo no 1833 dated 28.4.2022 and Vaishali District order no. 880/2022 passed by the Superintendent of police, Vaishali at Hajipur in departmental proceeding no. 67/21 whereby and where under the petitioner has been awarded punishment of stopping one year increment of the petitioner.
And the petitioner has been also been barred from from holding the post of Station Head Officer for the next 10 years.
3. The learned counsel for the petitioner submits that while the petitioner was posted as Station House Officer (SHO), Rajapakar Police Station, then on 12.10.2021 a first information report was lodged by one Atul Kumar giving rise to Rajakar P.S. Case No. 266 of 2021 under Sections 302, 328, 120(B) and 34 of the Indian Penal Code against named accused persons. One day prior to the date of occurrence, the petitioner on secret information conducted raid at a place as well as house
3/25 of one Shubham Kumar from where Homeopathic Medicine, some bottles of imperial blue wine, wine bottle wrappers, 12 empty bottle of 375 ml. imperial blue wine and 18 empty bottles of Royal Stag wine was recovered from the house of Shubham Kumar and upon enquiry the name of Bulbul Jha @ Rajesh Kumar Mishra transpired in doing illegal business of liquor, which resulted in lodging of Rajapakar P.S. Case No. 263 of 2021 dated 11.10.2021 under difference Sections of Bihar Prohibition and Excise Act, 2018. Subsequently, the house of Bulbul Jha @ Rajesh Kumar Mishra was raided where several empty bottles of Homeopathic medicine and poisonous liquor were recovered for which again a First Information Report bearing Rajapakar P.S. Case No. 267 of 2021 was registered.
4. It has further been submitted by the learned counsel for the petitioner that a report was submitted by the S.D.P.O., Mahua on 13.10.2021 before the Superintendent of Police, Vaishali wherein all the facts related to the death of father of Atul Kumar and the raids conducted by the petitioner and recovery of liquor and Homeopathic medicines were mentioned but no allegation of dereliction of duty was found against the petitioner. Again vide another letter on the same
4/25 date i.e. 13.10.2021 was issued under the signature of the S.D.P.O, Mahua adressed to the Superintendent of Police, Vaishali, a report was submitted with regard to Rajapakar Police Station case wherein it was informed that two FIRs were lodged against accused Bulbul Jha @ Rajesh Kumar Mishra and upon raid different Homeopathic medicines, liquor etc. have been found. Even in the said report, no allegation was made with regard to dereliction of duty against the petitioner.
5. The learned counsel for the petitioner submits that vide Memo No. 12544 dated 08.11.2021 issued under the signature of the Superintendent of Police, Vaishali, a showcause was issued to the petitioner that despite direction from the Police head quarter that the Officer In-charge of the Police Station concerned will be the investigating officer of the first serious offence registered in the Police Station of every month, but even then he gave investigation of Rajapakar P.S. Case No. 266 of 2021 to Pankaj Sharma. It was further mentioned in the show cause that total prohibition is there in the State of Bihar since April, 2016, but even then the petitioner is not taking interest in these type of occurrences and the petitioner was directed to submit his show cause reply within 24 hours that why departmental proceeding be not initiated against him. In
5/25 compliance thereof, the petitioner submitted his explanation/show-cause to the notice within the stipulated time i.e. 09.11.2021 whereby he denied all the charges levelled against him in the show cause notice, but the Superintendent of Police, Vaishali being not satisfied with the reply put the petitioner under suspension and departmental proceeding was initiated against him. The memo of charge was served upon the petitioner on 09.11.2021 wherein certain charges were levelled against him and the Sub Divisional Police Officer, Hajipur was appointed as a conducting officer and the Sub Inspector Pramod Kumar Singh of Hajipur was appointed as the presenting officer. The suspension of the petitioner was subsequently revoked on 08.12.2021.
6. The learned counsel for the petitioner further submits that after initiation of the departmental proceeding and after serving the memo of charge, no show cause notice/explanation was ever asked from the petitioner with regard to the charges levelled against him, while the enquiry officer proceeded ahead with the departmental proceeding without his knowledge. The petitioner on his own appeared before the conducting officer and submitted his explanation/show-cause on 23.03.2022 wherein he denied all
6/25 the charges levelled against him. Even after submission of the show cause reply, the petitioner was not provided with any opportunity by the conducting officer either to cross-examine the witnesses or to adduce his defence witnesses which is mandate of law as per the provisions contained under Rule 17(3) & (4) of the Bihar Government Servants (CCA) Rules, 2005. It has further been submitted that just after three days of submission of the show cause reply by the petitioner, the conducting officer submitted his enquiry report before the Superintendent of Police, Vaishali on 26.03.2022 wherein he found the charges to be proved against the petitioner. Thereafter, vide Memo No. 1535 dated 05.04.
2022 issued under the signature of the Superintendent of Police, Vaishali, the petitioner was issued second show cause notice and in compliance thereof, he filed a detailed reply to the second show cause notice before the Superintendent of Police, Vaishali, wherein he again denied the charges and explained in detail his conduct.
7/25 be equivalent to two black marks and debarred him from holding the post of Officer In-charge/S.H.O. for a period of 10 years. It was further directed that for the period under suspension, apart from the amount which has been paid to the petitioner, no further payments will be made to him and the suspension period will be adjusted in the half earned leave. Being aggrieved with the punishment order, the petitioner filed appeal before the appellate authority, but the appellate authority without considering the defence taken by the petitioner in his memo of appeal, proceeded to reject the appeal of the petitioner in a mechanical manner vide memo no. 3690 dated 01.10.2022.
7. The learned counsel for the petitioner submits that from the memo of charge it will appear that the charges against the petitioner were for negligence in keeping a watch upon the FIR named accused and for not investigating the case which was of serious nature, himself. It has further been contended by the learned counsel for the petitioner that it was due to effort of the petitioner that accused Bulbul Jha, who was an accused in three criminal cases and was absconding, was arrested and the petitioner, during his short tenure recovered huge quantity of NDPS and illegal liquor within the jurisdiction
8/25 of his police station. It has further been submitted that prior to institution of Rajapakar P.S. Case No. 266 of 2021, the petitioner had conducted raid at different places and recovered illicit liquor and Homeopathic medicines for which Rajapakar P.S. Case no. 263 of 2021 was instituted.
8. The learned counsel for the petitioner further submits that since on 11.10.2021, the petitioner proceeded for raid for recovery of illegal wine and Homeopathic medicines in the morning at 05:00 A.M. itself, due to which suffered from diarrhea, for which he was admitted in a hospital, therefore, the investigation of the case was handed over to the Pankaj Sharma. He further submits that the petitioner had sent the liquor and the Homeopathic medicine to the FSL laboratory on 13.11.2021 and the report was received on 12.01.2022, wherein it was found that ethyl alcohol along with methyl alcohol was available in the viscera and blood sample of the deceased.
9. Finally, the learned counsel for the petitioner submits that it is an admitted fact that the petitioner was never given any opportunity to submit his show cause reply before initiation of the departmental proceeding and the copy of the enquiry report was not handed over to the petitioner along with second show cause notice and he was not granted any
9/25 opportunity to cross-examine the witnesses as well as an opportunity to adduce defence witnesses in the departmental proceeding. The departmental proceeding was conducted in a hurry and the impugned order of punishment has been passed in violation of the principles of natural justice.
10. The learned counsel for the petitioner relies upon a judgment of the Hon'ble Supreme Court of India in Civil Appeal No. 1815 of 2007 in the case of Inspector Prem Chand Versus Government of N.C.T. of Delhi and Ors. Wherein in paragraph nos.5, 7, 8 and 9 the Hon'ble Supreme Court of India has held as follows:- "5. The original application filed by the appellant before the Central Administrative Tribunal, Principal Bench, Delhi, questioning the validity or legality of the said order of punishment as also the appellate order was dismissed by the Tribunal by its judgment dated 15.2.2005. A writ petition preferred there against by the appellant has been dismissed by a Division Bench of the Delhi High Court opining:
...We have also noted that in such a matter, if the plea of the petitioner is accepted and the accused not accepting the bribe money is to be a reason for not seizing the bribe
10/25 money there was no need to launch prosecution against the accused.
This not having been done resulted in the acquittal of the accused. The reasoning given by the Tribunal, therefore, does not warrant interference under Article 226 of the Constitution of India. The learned Counsel for the petitioner has further submitted that even if it is assumed that there is failure to seize the currency notes, this does not amount to misconduct. The Tribunal has analyzed various definitions of the word "misconduct" and we are in agreement with the conclusion of the Tribunal.
Furthermore, misconduct need not be founded on a positive act but can also be based upon an omission of duty required to be done by the public servant.
7.
Before adverting to the question Involved in the matter, we may see what the term 'misconduct' means. In State of Punjab and Ors. v. Ram Singh Ex.
Constable MANU/SC/0426/1992:
[1992]3SCR634, it was stated:
Misconduct has been defined in Black's Law Dictionary, Sixth Edition at page 999, thus:
11/25 A transgression of some established and definite rule of action, a forbidden act, a dereliction from duty, unlawful behavior, wilful in character, improper or wrong behavior, its synonyms are misdemeanor, offense, but not negligence or carelessness.
Misconduct in office has been defined as:
Any unlawful behavior by a public officer in relation to the duties of his office, willful in character.
Term embraces acts which the officer holder had no right to perform, acts performed improperly, and failure to act in the face of an affirmative duty to act.
8.
In P. Ramanatha Aiyar's Law Lexicon, 3rd edition, at page 3027, the term 'misconduct' has been defined as under:
The term 'misconduct' implies, a wrongful intention, and not a mere error of Judgment.
Misconduct is not necessarily the same thing as conduct involving moral turpitude.
The word 'misconduct' is a relative term, and has to be construed with reference to the subject matter and the context wherein the term occurs,
12/25 having regard to the scope of the Act or statute which is being construed.
Misconduct literally means wrong conduct or improper conduct.
[See also Bharat Petroleum Corpn. Ltd.
v. T.K. Raju (2006) IILLJ113SC MANU/SC/1083/2006:
9.
It is not in dispute that a disciplinary proceeding was initiated against the appellant In terms of the provisions of the Delhi Police (Punishment and Appeal) Rules, 1980. It was, therefore, necessary for the disciplinary authority to arrive at a finding of fact that the appellant was guilty of an unlawful behavior in relation to discharge of his duties in service, which was willful in character. No such finding was arrived at. An error of judgment, as noticed hereinbefore, per se is not a misconduct.
A negligence simpliciter also would not be a misconduct. In Union of India and Ors, v. J. Ahmed MANU/SC/0481/1979:
(1979)IILLJ14SC, whereupon Mr.
Sharan himself has placecd reliance, this Court held so stating:
Code of conduct as set out in the Conduct Rules clearly Indicates the conduct expected of a member of the service. It would follow that conduct which is blameworthy for the Government servant in the context of Conduct Rules would be
13/25 misconduct. If a servant conducts himself in a way inconsistent with due and faithful discharge of his duty in service, it is misconduct (see Pierce v. Foster 17 Q.B. 536, 542). A disregard of an essential condition of the contract of service may constitute misconduct [see Laws v. London Chronicle (Indicator Newspapers) 1959 1 WLR 698. This view was adopted in Shardaprasad Onkarprasad Tiwari v.
Divisional Superintendent, Central Railway, Nagpur Division, Nagpur MANU/MH/0220/1959:
(1960) ILLJ167Bom, and Satubha K.
Naghela v. Moosa Raza MANU/GJ/0109/1968:
(1969)10GLR23. The High Court has noted the definition of misconduct in Stroud's Judicial Dictionary which runs as under:
Misconduct means, misconduct arising from III motive; acts of negligence, errors of judgment, or innocent mistake, do not constitute such misconduct.
[Emphasis supplied]"
11. The learned counsel for the petitioner further relies on a judgment of the Hon'ble Supreme Court of India in Civil Appeal No. 7431 of 2008 in the case of Roop Singh Negi
14/25 Vs. Punjab National Bank and Ors. wherein in paragraph no.10, the Hon'ble Supreme Court of India has held as follows:- "10. Indisputably, a departmental proceeding is a quasi judicial proceeding. The Enquiry Officer performs a quasi judicial function. The charges leveled against the delinquent officer must be found to have been proved. The enquiry officer has a duty to arrive at a finding upon taking into consideration the materials brought on record by the parties. The purported evidence collected during investigation by the Investigating Officer against all the accused by itself could not be treated to be evidence in the disciplinary proceeding. No witness was examined to prove the said documents. The management witnesses merely tendered the documents and did not prove the contents thereof.
Reliance, inter alia, was placed by the Enquiry Officer on the FIR which could not have been treated as evidence. We have noticed hereinbefore that the only basic evidence whereupon reliance has been placed by the Enquiry Officer was the purported confession made by the appellant before the police.
According to the appellant, he was forced to sign on the said confession, as he was tortured in the police station. Appellant being an emplovee of the bank, the said confession should have been proved.
15/25 Some evidence should have been brought on record to show that he had indulged in stealing the bank draft book. Admittedly, there was no direct evidence. Even there was no Indirect evidence. The tenor of the report demonstrates that the Enquiry Officer had made up his mind to find him guilty as otherwise he would not have proceeded on the basis that the offence was committed in such a manner that no evidence was left.
12. The learned counsel for the petitioner further relies upon a judgment dated 10.12.2025 passed in C.W.J.C. No. 7478 of 2023 by a Co-ordinate Bench of this Court wherein in paragraph no.20 and 22, it has been held as follows:-
20. From the conspectus of the aforesaid two exhaustive decisions of the coordinate Benches of this Court is that the administrative authority acting in the capacity of a quasi-judicial authority can not enter and undertake a disciplinary proceeding imposing punishment, much less, revise and substitute it with a much harsher punishment with a per-determined mindset. The concept of strict liability by virtue of 'deemed guilt of a public servant in absence of any cogent material establishing direct connivance, complicity, negligence or involvement is totally alien to the service jurisprudence. A public servant, no doubt, has to act and perform
16/25 the duties of his office diligently and to the best of his abilities, but territorial responsibility can not be ipso facto equated with strict liability or deemed guilt, in absence of negligence or laxity being deliberate, which is evidenced based on cogent materials available on record.
22. As already noted by the afore-quoted decisions of the Coordinate Benches of this Court in Ajay Kumar (supra) and Mukesh Kumar Paswan (supra), that deemed guilt can not be sustained particularly in cases where there is a total absence of material to establish the guilt, connivance, complicity, negligence or laxity of the petitioner, independently.
13. The learned counsel for the petitioner further refers to and relies on a judgment dated 29.10.2024 passed by a Co-ordinate Bench of this Court in C.W.J.C. No. 8071 of 2023, wherein in paragraph no. 19, 22 and 27 it has been held as follows:-
19. As regard to the issue involved in the present case, I also find it proper to reproduce paragraph nos. 34, 35 and 42 of the judgment passed by a co-ordinate Bench of this Court in C.W.J.C. No. 737 of 2023 dated 05.05.2023, which is, inter alia, reproduced hereinafter:
34. Upon going through the entire materials as discussed hereinabove, this Court has no iota of doubt that
17/25 there was an inherent defect in the framing of charge itself inasmuch as a bare perusal of it would show that it has been framed on the direction of the Director General of Police, Bihar vide his letter no. 48 dated 29.11.2020 addressed to the Senior Superintendent of Police (Annexure '1' to the writ application). In this letter the Director General of Police has referred his own direction contained in letter no. 63 dated 24.11.2022, paragraph '3' whereof pre-judges the guilt of the S.H.O.
and the Chowkidar in case of recovery of illicit liquor from the area of the police station. This has no statutory sanction. Once the Director General of Police issued this direction to the S.SP, the S.S.P/S.P. had no opportunity to apply his own independent mind as to whether the petitioner is liable to be proceeded against or of the kind of charges may be framed against him. The direction was coming from the top of the police echelon as if on mere recovery of illicit liquor of 25 liters from the Kankarbagh Police Station area, the Officer-inCharge of the said police station is liable to be held guilty.
18/25
35. In the opinion of this Court, paragraph '3' of the letter no. 63 (01 fd;kU;0;u) 2019-20-1296/ elfu'ks/k dated 24.11.2020 which has influenced the entire proceeding right from the beginning, paragraph "3" raises a presumption of guilt even before framing of charge, therefore, this Court has no iota of doubt in saying that the guilt of the employee has been assumed and presumed even before giving him an opportunity of hearing. Such presumption of guilt has no sanction of law and the same is violative of Article 21 of the Constitution of India. It is contrary to the principles of fair play in action.
42. Before this Court parts with this order, in view of the discussions made hereinabove, this court directs the Director General of Police, Bihar, Patna (respondent No. 4) to revisit paragraph 3 of the letter no. 63 (01 fd;kU;o;u) 201920-1296/e/fu'ks/k dated 24.11.2020 which assumes and pre-judges the guilt against the Station House Officer and Chowkidar even before framing of charge and conduct of an independent enquiry. This has
19/25 no sanction of law. Because of this stipulation in this case the whole proceeding right from framing of charge has been influenced and a serious prejudice has been caused to the petitioner."
22. I further find that the Post Decisional hearing is one with close mind and it is a fact that it is detrimental in nature and it would be a formality in case it is done with a prejudiced mind with presupposed decision of awarding the punishment and hence post decisional hearing would not be as effective.
Furthermore, the basic prospect of natural justice requires pre decisional hearing and not post decisional hearing and the law granting post decisional hearing has been well settled by the Apex Court by holding that if the authorities have taken decision to take action before initiation of departmental proceeding, granting post decisional hearing will only be held to be an empty formality calling for violation of principle of natural justice.
27. Considering the facts and circumstances of the present case and the law laid down by the Apex Court referred in above paragraphs, I find that even though the petitioner was proceeded as per the provision of C.C.A. Rules, 2005 and opportunity of hearing was given to the
20/25 petitioner, in view of the conditions/directions contained in Letter No. 63 (01 implementation) 2019-201296/Excise Prohibition dated 24.11.2020 of the Director General of Police, in my opinion, the authorities had pre-determined to impose penalty on the petitioner and proceeded to hold quasi judicial inquiry giving the postdecisional opportunity of hearing which does not sub serve the rule of natural justice and is contrary to the principle of fair play. The authority who embarks upon decisional hearing will naturally proceed with a closed mind and there is hardly any chance of getting a proper consideration of the representation at such a post-decisional opportunity.
Accordingly, I set aside and quash the suspension order no. 21/2021-142 dated 01.02.2021 (Annexure-4 to the writ petition), charge memo contained in Memo No. 41 dated 09.02.2021 (Annexure-7 to the writ petition) and the penalty order contained in Memo no. 233 dated 13.04.2022 (Annexure-1 to the writ petition) and the subsequent orders, if any, are also hereby set aside and quashed.
14. Per contra, the learned counsel for the State submits that a report was submitted by the Deputy Superintendent of Police (Reserved) Poline Line, Hajipur from
21/25 which it is evident that while the petitioner was posted as S.H.O., Rajapakar Police Station, Rajapakar P.S. Case No. 266 of 2021 was instituted for the offences punishable under Section 302 and other allied sections of the Indian Penal Code and the petitioner received an information on 11.10.2021 that empty bottles of homeopathic drugs and English liquor have been thrown in a ditch, just by the side of the metalled road for which a raid was conducted and incriminating articles were recovered from the house of one Subham Kumar and for the said recovery Rajapakar P.S. Case No. 263 of 2021 was instituted.
15. It has further been submitted by the learned counsel for the State that due to dereliction of duty on the part of the petitioner, the blood sample of the deceased of Rajapakar P.S. Case no. 266 of 2021 was not sent to the FSL within time, which resulted in possibility of change of nature of sample. As per direction of the Police Headquarter, the case of serious nature registered as a first case of the month has to be investigated by the S.H.O. himself but the petitioner entrusted the investigation of the case to his junior. Further even after implementation of the complete ban of liquor from April, 2016 in the State of Bihar, none information of illegal
22/25 activity of consumption and sell of spurious liquor by the petitioner within his jurisdiction, adversely affected the working and shows his inefficiency and failure. The petitioner was asked to submit his show cause and on finding the reply submitted by the petitioner to be not satisfactory, the departmental proceeding was initiated against him and after enquiry and submission of the enquiry report wherein the investigating officer recommended for action against the petitioner, the disciplinary authority after giving opportunity to the petitioner to submit his second show cause reply, issued the impugned order of punishment. Even the appeal preferred by the petitioner has also been dismissed by the appellate authority and the same is a well discussed reasoned order.
16. Learned counsel for the State further submits that police being the State machinery has been empowered to ensure the implementation of the law framed by the legislature and the petitioner being the member of the disciplined force and holding the responsible post of S.H.O. had the duty to comply the law in its true letter and spirit within his jurisdiction and the recovery of huge quantity of incriminating materials like liquor and due to consumption of spurious liquor, five persons lost their life which clearly suggest
23/25 complete failure on the part of the petitioner and dereliction of duty.
17. The learned counsel for the State further submits that it has been admitted by the petitioner in his second show cause reply that 63 cases were registered by the petitioner with regard to Excise Act and 4660.800 ml of country made liquor along with 2292.453 ml foreign liquor, apart from things things were seized by the petitioner which shows that he failed to perform his duties properly.
18. From the arguments advanced on behalf of the parties and after going through the pleadings on record, I find that the petitioner was not given an opportunity to file his show cause reply to the memo of charge and the enquiry officer proceeded with the departmental proceeding wherein the petitioner is said to have himself appeared without any notice and the same has not been denied in the counter affidavit filed on behalf of the respondent authorities. From the records it appears that during course of enquiry, the petitioner did not choose to cross-examine any of the witnesses and after thorough enquiry, the enquiry officer submitted his report on 26.03.2022. The disciplinary authority gave opportunity to the petitioner to submit second show cause reply, but without
24/25 considering the same, he proceeded to pass the impugned order whereby the petitioner has been awarded punishment. From the judgments relied upon by the petitioner, it appears that Coordinate Benches of this Court have considered the fact that the disciplinary authority proceeded to award punishment with prejudged mind and even before framing of the charge, the authorities concerned had found the petitioner guilty. It is not the case that the petitioner has not done the investigation of any case improperly, rather the allegation was that in the area of the petitioner he failed to recover and stop the consumption of the illegal liquor.
By not giving opportunity to the petitioner to file show cause reply to the memo of charge, the respondent authorities have violated the principles of natural justice and further the copy of the enquiry report was also not provided to him and the same has not been controverted by the learned State counsel, therefore, based on the above findings, I am of the considered opinion that the order contained in Memo No. 1833 dated 28.04.2022 and Memo No. 3690 dated 01.10.2022 deserves to be set aside and are accordingly set aside.
19. The matter is remitted back to the disciplinary authority to proceed afresh from the stage of issuance of memo of charge itself. The entire exercise must be completed within a
25/25 period of six months from the date of production/receipt of a copy of the order.
20.
With the above-mentioned observations/directions, the present writ petition is allowed. (Ritesh Kumar, J) AjayMishra/- AFR/NAFR CAV DATE NA Uploading Date 18.02.2026 Transmission Date NA