THE STATE OF UTTAR PRADESH vs MOHAMMAD NOOH

The Supreme Court held that the District Superintendent of Police, who acted as both judge and witness in a departmental enquiry against a Head Constable, disqualified himself, violating principles of natural justice. The Court ruled that decisions based on such flawed procedures are invalid. However, it was determined that Article 226 of the Constitution is not retrospective, thus the High Court could not quash the dismissal order made prior to the Constitution's commencement. The appeal was allowed, reversing the High Court's decision.