MP High Court Quashes Tainted Inquiry Against GRMC Superintendent, Flags Breach of Natural Justice

The Madhya Pradesh High Court has quashed the entire departmental inquiry conducted against Dr. Girja Shankar Gupta, Superintendent at Gajara Raje Medical College (GRMC), Gwalior, holding that the proceedings were vitiated by repeated violations of principles of natural justice, even though the Dean was competent to issue the charge-sheet.

In its judgment dated February 17, 2026, in Writ Petition No. 50553 of 2025, Justice Ashish Shroti observed that “the principles of natural justice are breached at every stage in this case, right from the issuance of charge sheet till submission of report by Enquiry Officer”.

Dr. Gupta had approached the High court challenging the charge-sheet dated October 30, 2025, the ex-parte inquiry conducted by the Enquiry Officer, and the report dated December 31, 2025. He also sought restoration to the post of Superintendent and quashing of the inquiry report. He was represented by Advocate Prashant Sharma. The State was represented by Government Advocate Dharmendra Nayak, while Advocate D.P. Singh appeared for respondent No. 3 and Advocate Chandra Prakash Sharma represented respondent Nos. 4 (Enquiry Officer) and 5 (Presiding Officer).

The controversy stemmed from allegations that Gupta had secured his appointment on the basis of false documents. Initially, a charge-sheet dated November 21, 2025 was issued under the joint signatures of the Enquiry Officer and the Presenting Officer. This was later withdrawn on the ground that the Dean had already issued a charge-sheet on October 30, 2025. However, the court noted that the October 30 charge-sheet was not served on the petitioner until December 16, 2025, when it was forwarded by the Enquiry Officer.

The petitioner contended that the Dean was not the competent authority under the Madhya Pradesh Super Specialty Hospital Rules, 2018, and that only the Commissioner, Medical Education could initiate disciplinary action. The respondents, however, argued that Gupta was governed by the Madhya Pradesh Swashasi Chikitsa Mahavidyalaya Chikitskiya Seva Adarsh Niyam, 2018 (Autonomous College Rules of 2018), under which the Dean is the disciplinary authority.

After examining the appointment order and the applicable rules, the court concluded that Gupta was appointed in the pay band prescribed under the Autonomous College Rules of 2018 and not under the Super Specialty Hospital Rules. It held that “the CEO/Dean of the College was thus competent to take disciplinary action and issue charge sheet against the petitioner”, rejecting the challenge to the Dean’s authority.

However, the court found serious infirmities in the conduct of the inquiry. It emphasized that an Enquiry Officer acts in a quasi-judicial capacity and must remain independent and unbiased. Relying on State of U.P. vs. Saroj Kumar Sinha and Union of India vs. Naseem Siddiqui, the court reiterated that an Enquiry Officer cannot assume the role of a prosecutor.

The High court flagged multiple irregularities: the initial charge-sheet jointly signed by the Enquiry Officer and Presenting Officer; the withdrawal of that charge-sheet; the service of the Dean’s charge-sheet through the Enquiry Officer; and finally, the inquiry report being jointly signed by both the Enquiry Officer and the Presenting Officer.

“This is unacceptable inasmuch as signing of report by the Presenting Officer would only mean that he is instrumental in recording of findings against the petitioner,” the court observed. It further noted that no evidence was led by the Presenting Officer to establish the charges and that findings were recorded without formal proof of documents.

Rejecting the respondents’ submission that the officers were doctors unfamiliar with inquiry procedure, the court remarked that conducting an inquiry by a person not well-versed with the process is a “serious lapse,” especially when the findings may culminate in removal from service.

While holding that questions regarding supply of documents and opportunity of hearing were premature at this stage, the court nonetheless concluded that the manner in which the inquiry was conducted could not be sustained.

Accordingly, the High court quashed the entire exercise conducted by the Enquiry Officer and Presenting Officer and directed the Dean to proceed afresh from the stage of service of charge-sheet. It clarified that the petitioner would be entitled to copies of all relied-upon documents and any other documents shown to be relevant.

The petition was thus partly allowed.

Case Title: Dr. Girja Shankar Gupta v. The State of Madhya Pradesh and Others

Date of Order: February 17, 2026

Bench: Justice Ashish Shroti