R.P. KAPUR vs PRATAP SINGH KAIRON AND OTHERS

The Supreme Court examined the applicability of Section 2 of the Public Servants (Inquiries) Act, 1850, in the context of an enquiry ordered against a member of the Indian Civil Service. The Court established that three conditions must be met for such an enquiry: (1) the Government must have good grounds for the enquiry, (2) it must be directed against a servant in its service, and (3) the servant must not be removable without Government sanction. The Court held that all three conditions were satisfied in this case, affirming the validity of the enquiry ordered by the Punjab Government.