STATE OF PUNJAB vs KISHAN DASS

The Supreme Court held that the order reducing the respondent's salary to the starting point for constables constituted a reduction in rank under Article 311(2) of the Constitution. The Court emphasized that even though the respondent was not moved from a higher to a lower post, the reduction in emoluments and its impact on seniority and promotion opportunities triggered the procedural safeguards of Article 311(2). Consequently, the Court upheld the lower courts' decisions that the order was vitiated due to the lack of a show cause notice prior to the action taken against the respondent.