Secretary, Forest Dept. & Ors vs Abdur Rasul Chowdhury

The Supreme Court held that under Article 21 of the Constitution of India, a retired employee cannot be subjected to disciplinary proceedings after retirement, as there is no provision allowing continuation of such proceedings post-superannuation. The Court emphasized that the delay in completing the departmental inquiry, initiated in 1987, violated the principles of natural justice. Consequently, the Court upheld the High Court's decision to quash the ongoing disciplinary proceedings against the respondent and directed the release of his retirement benefits.