PARAMJIT SINGH vs DIRECTOR, PUBLIC INSTRUCTIONS .

The Supreme Court held that the termination of probationary teachers by Khalsa High School was not penal in nature, thus no departmental inquiry was required prior to termination. The Court emphasized that while the termination was lawful due to unsatisfactory performance, the mandatory prior approval under Section 4 of the Punjab Privately Managed Recognized Schools Employees (Security of Service) Act, 1979 was not obtained, rendering the termination invalid. Consequently, the Court upheld the Tribunal's direction for reinstatement with back wages, affirming the necessity of compliance with statutory requirements.