STATE OF GUJARAT vs AKHILESH C. BHARGAV & ORS.

The Supreme Court held that under Rule 12(bb) of the Indian Police Service (Probation) Rules, 1954, the first respondent had become a confirmed officer and could not be discharged without due process as required under Article 311(2) of the Constitution of India. The Court clarified that the absence of an extension order did not invalidate the confirmation after the probation period, and the administrative instructions issued were valid to fill any gaps in the rules. The appeal by the State was dismissed, affirming the High Court's decision to annul the discharge order.