STATE OF PUNJAB vs BALBIR SINGH

The Supreme Court held that the discharge of a Constable under Rule 12.21 of the Punjab Police Rules, 1934, was not punitive and did not violate Article 311(2) of the Constitution of India, as it was based on the assessment of efficiency within the first three years of service. The Court distinguished between termination based on contractual rights and punitive actions requiring a disciplinary inquiry. The High Court's ruling that the discharge was illegal was overturned, affirming the validity of the discharge order.