Union of India v. R. S. Bhatnagar was a 1978 judgment of the Supreme Court of India. The case involved a challenge to a departmental inquiry that had been initiated against the respondent, R. S. Bhatnagar, who was an employee of the Union of India. The respondent argued that the inquiry was being conducted mala fide, and that the charges against him were frivolous or vexatious.
The Supreme Court held that the High Court should not interfere with a departmental inquiry unless it is satisfied that the inquiry is being conducted mala fide, or that the charges are frivolous or vexatious. The Court observed that departmental inquiries are held for the purpose of determining the guilt or innocence of an employee, and that it is not for the courts to substitute their own judgment for that of the department in such matters.
The Court further held that if the charges against an employee are false and frivolous, the employee is entitled to claim compensation from the department for the harassment caused to him. The Court also held that the High Court should not quash a departmental inquiry on the ground that the charges are not proved or not established, unless it is shown that the inquiry is being conducted mala fide or with the ulterior motive.
The Court also held that the High court has the power to quash the inquiry if the inquiry officer is not impartial.
