Airports Authority of India v. Pradip Kumar – Natural Justice Case [2025]

                             AUTHOR NAME- Snehil Singh, B.A. L.L.B., Fifth Year.

                    NAME OF INSTITUTION: Babu Banarasi Das University, Lucknow

Citation: [2025] 2 S.C.R. 404	Case Type: Civil Appeal /8414/2017
Date of Judgement: 04 February 2025	Judgement by: Hon’ble Mr. Justice Sandeep Mishra
Petitioner: Airports Authority of India	Respondent: Pradip Kumar Banerjee
Disposal: Appeal allowed	Order/ Judgement: Judgement

FACTS:

In this case Respondent, Pradip Kumar Banerjee, was an employee of the Airports Authority of India (AAI). During the discharge of his duty, he was charged in a case related to misconduct in the discharge of his official duty. So an inquiry was conducted in which the inquiry officer submitted a report in which the respondent was held guilty of the offence, but no copy of the same report was given to the respondent so that he could explain anything or respond to it. Without such act was done the punishment was given to the respondent so, for the case thing he has filled an appeal in the high court by saying that his grounds of natural were violated, court by seeing that quashed the punishment by holding the failure of the authority and has violated the rule of natural justice. The AAI was not satisfied with the decision given by the High Court, so they have challenged their decision in the Supreme Court.

ISSUE RAISED:

Whether a failure to provide a copy of the inquiry report to the Employee of the company (Pradip) before imposing the penalty on him due to a violation of the principles of natural justice?

RULE OF LAW:

Here the mentioned rules are:

• Audi Alteram Partem (Right to be heard):

Every individual basically has the right to defend themselves before any serious action is taken against them.

• Fair Procedure in Disciplinary Proceedings:

Any of the employee facing the disciplinary action against him/ her must be given all the details and documents so that he can defend himself before the final decision is made.

REASONING:

The reason behind the judgement of the Supreme Court is mentioned below:

• The employee has the right to receive a copy of an inquiry report before any final decision has been made. The person must be given a chance in order to defend himself from any of the problem.
• The Airports Authority of India did not even provide a chance to defend himself when the inquiry report was submitted; it took away an opportunity for the employee to present his defense effectively.
• Fair procedure is an essential part of service jurisprudence.

HELD:

The Supreme Court of India has dismissed the appeal filed by the Airports Authority of India by saying that the High Court was Right in quashing the punishment order as it was based on a procedurally unfair disciplinary process. It has stated that the principles of natural justice are violated; hence, the punishment imposed on the employee or the respondent could not be sustained.

BIBLIOGRAPHY:

Case name- AIRPORTS AUTHORITY OF INDIA vs. PRADIP KUMAR BANERJEE (Civil Appeal No. 8414 of 2017)[i]

For the Full Document, click on the mentioned link: https://digiscr.sci.gov.in/admin/judgement_file/judgement_pdf/2025/volume%202/Part%20II/2025_2_404-423_1740807355.pdf

[i] (2025 INSC 149).