Madhya Pradesh High Court Upholds Dismissal Of Scindia School Employee Over Tobacco Sale On Campus

The High Court of Madhya Pradesh has dismissed a decade-old service dispute filed by a Class-IV employee of The Scindia School, holding that no case for interference was made out against a Labour court award upholding his dismissal for selling tobacco products within the school campus.

Justice Anand Singh Bahrawat rejected the writ petition filed by Prayagnarayan, who had challenged the termination of his services and the subsequent award of the Labour Court, Gwalior. The petitioner had sought quashing of the charge-sheet and dismissal order, reinstatement with continuity of service from July 11, 2012, and payment of back wages.

Appearing for the petitioner, Shri Prem Singh Pal argued that the employee had served the institution since July 8, 1984, and had completed 28 years of blemish-free service before being abruptly charge-sheeted. It was contended that copies of documents and statements of management witnesses were not supplied along with the charge-sheet, that the inquiry officer was a junior colleague-advocate of the employer, and that the petitioner, being illiterate, was made to sign documents without understanding their contents. The petitioner relied on judicial precedents including Prem Nath Bali v. Registrar, High Court of Delhi to argue that the inquiry was vitiated for non-compliance with principles of natural justice.

Opposing the plea, Ms. Chitra Bais, appearing for the school, submitted that the domestic inquiry was conducted strictly in accordance with the Service Rules and Standing Orders governing the institution. She pointed out that there was no rule mandating annexure of documents with the charge-sheet and that, pursuant to an application before the Labour court, all relevant documents were supplied, including a video CD. Crucially, the management asserted that the petitioner had admitted the charges in his written reply to the charge-sheet as well as in response to a show-cause notice dated June 29, 2012.

The charges related to the sale of tobacco, cigarettes, bidi and gutka within the school campus: an act prohibited by governmental directions applicable to educational institutions. The school argued that the petitioner resided within the campus premises, where students attended classes and stayed in hostels, and that the misconduct was of a serious nature warranting dismissal.

After examining the record, the court held that the inquiry had been conducted in accordance with the applicable service rules and that the Labour court had duly considered the pleadings and evidence. The court noted that the petitioner had suppressed material facts regarding his admission of guilt and that he had been afforded adequate opportunity to lead defence evidence. The appointment of a colleague-advocate as inquiry officer, the court observed, was permissible under the service rules and did not ipso facto vitiate the proceedings.

Emphasising the limits of supervisory jurisdiction, the court relied on Supreme Court authorities including Iswarlal Mohanlal Thakkar v. Paschim Gujarat Vij Company Ltd., and Jai Singh v. Municipal Corporation of Delhi to reiterate that the High Court cannot reappreciate evidence as an appellate court under Article 227. Quoting from precedent, the court observed that the power of interference must be exercised with “great care, caution and circumspection” and not “like a bull in a china shop” to correct every error of judgment.

Finding no perversity or patent illegality in the Labour court’s award, the court concluded that the punishment imposed was commensurate with the gravity of misconduct and that the petition was “sans substance.” The writ petition was accordingly dismissed.

Case Title: Prayagnarayan v. Principal Scindia School Fort Gwalior

Date of Order: February 19, 2026

Bench: Justice Anand Singh Bahrawat