THE STATE OF ASSAM AND ANOTHER vs MAHENDRA KUMAR DAS AND OTHERS

The Supreme Court held that a departmental enquiry is not vitiated if the enquiry officer consults outside sources, provided that such material is not relied upon in the decision-making process. The Court clarified that while it is improper for an enquiry officer to collect materials behind the delinquent officer's back, if the officer's conclusions are based solely on disclosed evidence, the enquiry remains valid. The Court overturned the High Court's ruling, affirming the dismissal of the respondent as the enquiry was conducted fairly without reliance on undisclosed materials.