THE STATE OF UTTAR PRADESH vs MADAN MOHAN NAGAR

The Supreme Court held that the order of compulsory retirement under Article 465A of the U.P. Civil Service Regulations, stating that the respondent had 'outlived his utility', casts a stigma and amounts to punishment. The Court applied the tests from Shyam Lal's case, determining that the imputation of having outlived utility was a condition for the exercise of power, thus constituting a punitive action. The High Court's decision to quash the order was upheld, reinforcing the principle that compulsory retirement cannot be used as a means of punishment without due process.