CENTRAL BANK OF INDIA vs C. BERNARD

The Supreme Court held that the order passed by the Enquiry Officer was without jurisdiction due to his retirement, rendering him incompetent to impose punishment on the delinquent employee. The Court clarified that the de facto doctrine does not apply as the Enquiry Officer was not in possession of an office with duties affecting the public, and thus his actions could not be validated post-retirement. The appeal was allowed in part, but the High Court's direction for payment of consequential benefits was deemed erroneous.