SHIVAJI ATMAJI SAWANT & ANR. vs STATE OF MAHARASHTRA AND ORS.

The Supreme Court held that under Section 25 of the Bombay Police Act, 1951, and Article 311(2) of the Constitution, the recording of reasons for dispensing with an inquiry is a prerequisite for validity. The Court found that the dismissal orders of the appellants were valid as they contained reasons for not holding an inquiry, thus upholding the dismissal. The Court emphasized that while cyclostyled orders may suggest non-application of mind, this is not an absolute rule and must be assessed based on the specific facts of the case.