KRISHNA BALLABH SAHAY AND ORS. vs COMMISSION OF ENQUIRY & ORS.

The Supreme Court held that under Article 156(3) of the Constitution, a Governor continues to hold office beyond the expiration of his term until a successor is appointed, thus rejecting the appellants' claim of the Governor being functus officio. The Court affirmed that a succeeding ministry has the authority to order an inquiry into the conduct of outgoing ministers to prevent corruption from going unchecked. The appeal was dismissed, emphasizing the necessity of scrutiny in public life, regardless of the merits of the charges against the ministers.