Coal Mines P.F.Commr.Tr.Board Of ... vs Ramesh Chandra Jha

The Supreme Court held that the Coal Mines Provident Fund Commissioner is a 'public officer' under Section 2(17) of the Code of Civil Procedure, necessitating notice under Section 80 CPC before filing a suit against him. The Court affirmed the principle that removal from service must adhere to the principles of natural justice and Article 311 of the Constitution. The judgment of the lower court was set aside due to the non-joinder of the Union of India, which was deemed a necessary party under Section 79 CPC.