A. L. Ramanathan v. Jawaharlal Nehru University

$~145 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 7049/2026 & CM APPL. 34558/2026 A. L. RAMANATHAN .....Petitioner Through:

Mr. Padma Kumar S., M. Padmam and Mr. Gurpreet Singh, Advocates.

versus JAWAHARLAL NEHRU UNIVERSITY .....Respondent Through:

Mr. Karan Prakash, Ms. Deepshikha Kumar and Mr. Om Bali, Advocates.

CORAM:

HON'BLE MR. JUSTICE SANJEEV NARULA

O R D E R

% 20.05.2026 1.

The Petitioner, a former Senior Professor with the Respondent University/Jawaharlal Nehru University,1 having served the institution for nearly two decades, assails order dated 21st April, 2025 passed by the Disciplinary Authority imposing upon him the penalty of dismissal from service. The appeal preferred by the Petitioner against the said order also came to be rejected by what has been described as a "Review Order" dated 14th October, 2025, founded upon the minutes of the meeting of the University Court held on 10th October, 2025.

2.

The brief facts relevant for adjudication of the present petition are that the Petitioner joined the services of JNU as a Professor in the School of Environmental Sciences in the year 2000. On 25th May, 2022, a charge memorandum came to be issued to the Petitioner enclosing certain articles of W.P.(C) 7049/2026 Page 1 of 9 The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

charge and proposing initiation of disciplinary proceedings against him. The Petitioner was simultaneously called upon to submit his written statement of defence. It is the case of the Petitioner that, without awaiting his written statement of defence, the Respondents proceeded to appoint the Inquiry Officer and commenced the disciplinary inquiry. 3.

Mr. Padma Kumar S., counsel for the Petitioner, submits that the departmental inquiry was conducted in gross violation of principles of natural justice and fair procedure. It is contended that adequate opportunity of defence was not afforded to the Petitioner and the original documents relied upon in the inquiry were not furnished to him. He submits that substantial prejudice has been caused to the Petitioner inasmuch as he was denied an effective opportunity to contest the proceedings, including the right to cross-examine witnesses. It is further contended that the documents sought by the Petitioner were also not supplied and even his request for summoning witnesses was declined.

4.

On merits as well, counsel submits that despite there being no substantive evidence of misconduct, the Inquiry Officer returned findings against the Petitioner by erroneously equating supervisory responsibility with culpability, while completely disregarding the statutory division of financial responsibilities within the University framework. 5.

All these aspects, it is submitted, were specifically delineated and explained in the detailed representation dated 15th January, 2025 submitted by the Petitioner against the inquiry report, raising several grounds both on merits as well as on procedural infirmities. However, the Disciplinary Authority failed to take the said representation into consideration while 1 "JNU"

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passing the penalty order, thereby rendering the decision-making process arbitrary, mechanical and vitiated for non-application of mind. 6.

In such circumstances, the Petitioner has approached this Court seeking setting aside of the inquiry report dated 4th November, 2024, the penalty order dated 21st April, 2025 and the review order dated 14th October, 2025.

7.

The Court has considered the submissions advanced by the Petitioner as well as perused the impugned orders. A perusal of the penalty order dated 21st April, 2025 reveals that, apart from reproducing the factual background and the conclusions of the Inquiry Officer, the Disciplinary Authority has proceeded to impose the penalty of dismissal from service without any discussion of the Petitioner's defence or the objections raised in the representation dated 15th January, 2025. The operative part of the order merely records that, upon following due process and considering the available facts, the penalty of dismissal from service is imposed upon the Petitioner. The order, thus, does not disclose any independent analysis or application of mind by the Disciplinary Authority to the contentions raised by the Petitioner. For ease of reference, the order is extracted hereinunder: No.ACAD.II/SES/57 Date: 21.04.2025

ORDER

Whereas an official departmental enquiry was conducted against Prof. A. L. Ramanathan of the School of Environmental Sciences, pursuant to allegations of financial irregularities received through the Office of the Chief Vigilance Officer, JNU.

And whereas in pursuance of the aforesaid enquiry, Prof. A. L. Ramanathan was placed under suspension vide a suspension order dated 30.09.2021.

And whereas the Departmental Enquiry Committee submitted its findings in form of an Enquiry Report on 04.11.2024.

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And whereas, based on the findings, the Enquiry Officer concluded that the charges levelled under Article 2 of the Enquiry Report, stand substantiated. It has been further recorded that the nature of proven charges may be construed to fall within the ambit of "major penalty" as defined under the relevant rules and statutory provisions of civil service applicable to the University. Furthermore, as per the Enquiry Officer's assessment, the findings indicate the commission of what may be interpreted as "grave financial irregularities" by Prof. A. L. Ramanathan.

And whereas the Executive Council, in its meeting held on 16 April 2025 and recorded in Executive Council Resolution No. 6.10(A), after due deliberations, resolved to approve the dismissal of Prof. A. L. Ramanathan, School of Environmental Sciences, without any service or retirement benefits from the University, with immediate effect, in accordance with Rule 11(ix) of the Central Civil Services (Classification, Control and Appeal) Rules. Additionally, the Council suggested exploring the legal avenues available to the University for recovering any pecuniary losses.

Upon following the due process and considering all available facts, the penalty of dismissal from the University's service is hereby imposed on Prof. A. L. Ramanathan, School of Environmental Sciences of the University, with immediate effect.

Sd/- (Santishree D. Pandit) Vice Chancellor"

8.

Aggrieved, the Petitioner preferred an appeal/review against the aforesaid order, which came to be considered by the "University Court" of the Respondent University in its 52nd meeting held on 10th October, 2025. The minutes of the review proceedings read as under: "Minutes of the Review [undertaken by the University Court under Section 11(2) of the JNU Act, 1966] Item No. 08: The case of Prof. A. L. Ramanathan The University Court, convened in its 52nd meeting on 10 October 2025, to consider Item No. 8 of the agenda, relating to Prof. A. L. Ramanathan, a former Professor of the School of Environmental Sciences, who sought a review of the Executive Council's resolution 6.10(A) adopted in its 322nd meeting, dismissing Prof. Ramanathan from service following the findings of an independent inquiry. W.P.(C) 7049/2026 Page 4 of 9 The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

Under Section 11(2) of the JNU Act, 1966, the University Court may review the acts of the Executive Council and Academic Council, except where confirmed by the Visitor. The Court's review is limited to verifying that the decision taken by the Executive Council is within jurisdiction, complies with Statutes and Ordinances, and follows the due process of law based on the documents available on record. Findings of the Court The Court has examined the papers pertaining to the case of Prof. Ramanathan attached in the Court's agenda.

The charges against Prof. A. L. Ramanathan, being in the nature of grave financial irregularities, have been duly established through an independent and impartial inquiry conducted in accordance with the prescribed procedure.

Having reviewed the record within its limited scope of jurisdiction, the Court finds no ground to interfere with or reopen the findings of guilt recorded against him. The materials placed before the Court sufficiently demonstrate that the disciplinary proceedings were conducted in conformity with due process of law, that adequate opportunity of defence was afforded, and that the penalty imposed is proportionate to the gravity of the proven misconduct involving public funds. All other grounds urged in the review petition have been duly examined by the Court and are found to be devoid of merit and do not warrant further comment under Section 11(2) of the JNU Act, 1966." 9.

The decision of the University Court was thereafter communicated to the Petitioner vide communication dated 14th October, 2025, which reads as follows:

"Subject:

Communication of the decision of the University Court on your review representation under Section 11(2) of the JNU Act, 1966 Dear Professor Ramanathan,

1. I write as Secretary to the University Court to convey the decision taken by the Court at its 52nd meeting held on 10 October 2025 on Agenda Item 8 concerning your review representation against Executive Council Resolution 6.10(A) adopted at the 322nd meeting on 16 April 2025.

2. The University Court reviewed the matter within the scope prescribed by Section 11(2) of the JNU Act, 1966.

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3. Upon consideration, the Court recorded that the charges, being in the nature of grave financial irregularities, had been duly established through an independent inquiry conducted in accordance with prescribed procedure, and that adequate opportunity of defence was afforded. The University Court further found that the penalty is proportionate to the gravity of proven misconduct involving public funds. No ground for interference on jurisdictional or procedural grounds was found.

4. The University Court resolved to reject your review representation and to uphold Executive Council, stands affirmed.

5. This communication is being issued pursuant to the court's direction that decisions be notified by the Secretary of the Court. For completeness, it is noted that certain members of the Executive Council who were directly involved in the resolutions under review did not participate in the deliberations on Agenda Item 8 in the interest of propriety.

6. You may treat this letter as formal intimation of the decision of the University Court on your review representation." 10.

A perusal of the aforesaid communication, read together with the minutes of the University Court, reveals that the Petitioner's objections have not been specifically dealt with. The Appellate/Review Authority, while affirming the order of the Disciplinary Authority, has proceeded in a largely perfunctory manner by recording broad conclusions without adverting to the detailed grounds urged by the Petitioner in the review representation. Although the University Court records that it examined the matter within the limited scope of jurisdiction available under Section 11(2) of the JNU Act, 1966, neither the minutes nor the consequential communication disclose any meaningful consideration of the Petitioner's specific grievances relating to denial of adequate opportunity, non-supply of documents, refusal to summon witnesses, alleged procedural irregularities during the inquiry proceedings, or the challenge laid to the findings returned by the Inquiry Officer on merits.

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11.

This, in the opinion of the Court, does not meet the touchstone required in disciplinary proceedings entailing serious civil consequences. Even if the scope of review before the University Court was limited, the same did not absolve the authority from considering the principal grounds urged by the Petitioner and disclosing, at least briefly, the reasons which weighed with it while rejecting the challenge. The impugned review order, however, merely reproduces broad conclusions regarding compliance with due process and proportionality of punishment without indicating any independent evaluation of the Petitioner's contentions. 12.

The Supreme Court in Kranti Associates (P) Ltd. v. Masood Ahmed Khan,2 emphasised that a quasi-judicial authority must record reasons in support of its conclusions. The Court underscored that recording of reasons is an indispensable component of a fair decision-making process and acts as a restraint against arbitrary exercise of power. The Supreme Court further held that insistence on reasoned orders is a requirement of transparency and accountability, and that reasons in support of decisions must be cogent, clear and succinct. "Rubber-stamp reasons" cannot be equated with a valid decision-making process.

13.

Further, in Allahabad Bank v. Krishna Narayan Tewari,3 the Supreme Court observed that the writ court would be justified in interfering with disciplinary orders where the inquiry stands vitiated on account of violation of principles of natural justice, non-application of mind, or nonrecording of reasons by the Enquiry Officer or the Disciplinary Authority. The Court observed that where the disciplinary authority fails to properly 2 (2010) 9 SCC 496.

3 (2017) 2 SCC 308.

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appreciate the evidence or record reasons in support of its conclusions, and the Appellate Authority merely reproduces the findings of the Disciplinary Authority without independently examining the matter, such failure strikes at the fairness of the decision-making process and results in miscarriage of justice.

14.

In disciplinary proceedings resulting in grave civil consequences, particularly where the penalty imposed is dismissal from service, the requirement of a reasoned and speaking order assumes heightened significance. The absence of any discussion or analysis of the Petitioner's objections in both the penalty order as well as the review order, thus, renders the impugned decisions vulnerable on the ground of non-application of mind.

15.

In light of the foregoing, and without delving into the merits of the allegations or the findings recorded in the inquiry report, the impugned penalty order dated 21st April, 2025, the minutes of meeting dated 10th October, 2025 as well as the review order dated 14th October, 2025 are set aside. The matter is remanded back to the Disciplinary Authority to consider the Petitioner's representation dated 15th January, 2025 afresh and pass a reasoned and speaking order dealing with the Petitioner's contentions, within a period of eight weeks from today.

16.

It is clarified that this Court has expressed no opinion on the challenge to the inquiry report. The Petitioner's contentions in this regard, if any, are left open to be urged before the Disciplinary Authority. 17.

Should the decision ultimately taken by the Disciplinary Authority be adverse to the Petitioner, it shall be open to him to avail of such remedies as may be available in accordance with law.

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18.

The Court has not commented on the merits of the case. All rights and contentions of the parties are left open.

19.

With the aforesaid directions, the present petition, along with pending application, stands disposed of.

SANJEEV NARULA, J MAY 20, 2026 as W.P.(C) 7049/2026 Page 9 of 9 The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.