S. L. AGARWAL vs GENERAL MANAGER, HINDUSTAN STEEL LTD.

The Supreme Court held that Article 311 of the Constitution does not apply to employees of Hindustan Steel Ltd. as it is not a department of the Government, and the appellant, an Assistant Surgeon, does not hold a civil post under the Union or State as defined in Article 311(1). The Court affirmed the High Court's dismissal of the appellant's petition, stating that the company operates independently and is financed through share capital, thus lacking the necessary connection to the Consolidated Fund of the Union. The appellant's arguments regarding the validity of the departmental enquiry were not considered as they were not raised in the High Court.