S. JANAKI IYERversusUNION OF INDIA & ORS.

                  [2025] 5 S.C.R. 961 : 2025 INSC 742

                              S. Janaki Iyer
                                     v.
                           Union of India & Ors.
                       (Civil Appeal No. 10858 of 2024)
                                  20 May 2025
           [Abhay S. Oka and Augustine George Masih,* JJ.]


                            Issue for Consideration
       Whether the impugned orders sustaining dismissal of the appellant
       from the service requires interference; whether there was any
       violation of statutory rules; whether there was violation of principles
       of natural justice; whether, in the instant case, there is ample
       evidence to establish that the transfer order dated 01.10.1991,
       which solely benefited appellant, was fake.

                                   Headnotes†
       Central Civil Services (Classification, Control and Appeal)
       Rules, 1965 – Allegation against the appellant that she had
       managed to get herself transferred from Kendriya Vidyalaya,
       Bangalore to Kendriya Vidyalaya, Bombay under a fake transfer
       order – Chargesheet was filed – Disciplinary Authority found
       appellant guilty of charges – Appellant was dismissed from
       service as appellant was sole beneficiary of the said transfer
       order – A statutory appeal filed before the Appellate Authority
       was rejected – CAT and the High Court also upheld the
       order of dismissal – Appellant, inter alia, contended that the
       chargesheet was vague and principles of natural justice were
       not adhered to by respondents while passing the dismissal
       order – Correctness:
       Held: A perusal of the chargesheet dated 10.02.1993 would show
       that not only did it contain the charges against the appellant but
       the same was supported by documents as well – The language
       of the said chargesheet is very clear and specific – She was the
       sole beneficiary of a fake transfer order – The plea therefore with
       regard to the vagueness of the chargesheet cannot be sustained –
       No prejudice having been caused because of the non-supply of


* Author
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       the preliminary Inquiry Report to the appellant, the plea of violation
       of the principles of natural justice would not be available to the
       appellant – Nothing has also come on record which would indicate
       that the appellant had ever sought for the Preliminary Inquiry Report
       after the issuance of the chargesheet – Similar would be the position
       with regard to the other documents also which are alleged to have
       not been supplied to her as the nature and extent of disadvantage
       or handicap caused or suffered by the appellant, in the absence
       of the documents, is missing in the departmental proceedings or
       the pleadings – As far as prolongation of the inquiry for 9 years
       is concerned, inordinate or unexplained delay in the departmental
       proceedings may be a justifiable ground if tampered with prejudice
       having been established to have been caused to the delinquent
       employee in the said process for interference by the Court – In the
       present case, the same is absent and therefore the said plea of
       delay fails – As far as statutory rules are concerned, the procedure
       in Rule 15(2), CCS(CCS) Rules, 1965 was duly complied with and
       followed – As regards the submission that the findings as recorded
       by the Inquiry Officer with regard to the transfer order being fake
       are based on no evidence, it falls flat when the alleged author
       himself denying the said signatures on the document and has gone
       to the extent of saying that he had not issued the said order, the
       requirements of the statutory rules in a departmental inquiry stand
       fulfilled – The preponderance and probability being the touchstone
       in the departmental proceedings the same having been fulfilled, the
       plea as sought to be raised by the appellant cannot sustain – The
       impugned orders being in accordance with law do not call for any
       interference. [Paras 21, 22, 26, 28, 29]

       Principles of Natural Justice – Three Fundamental Rules –
       Hearing Rule (Audi Alteram Partem) – Bias Rule (Nemo Judex
       in Causa Sua) – Principle of Reasoned Decision, also known
       as Speaking Orders:
       Held: The principles of natural justice are founded on three
       fundamental rules that ensure fairness in legal and administrative
       proceedings – Firstly, the Hearing Rule (Audi Alteram Partem)
       which mandates that no person should be judged without being
       given a fair opportunity to present his case – Secondly, the Bias
       Rule (Nemo Judex in Causa Sua) which asserts that no one
[2025] 5 S.C.R.                                                             963

                    S. Janaki Iyer v. Union of India & Ors.


     should act as a judge in its own case, thereby safeguarding
     impartiality and preventing any form of bias – Lastly, the principle
     of Reasoned Decision, also known as Speaking Orders, requires
     every decision to be supported by valid and clearly stated reasons
     to promote transparency and accountability in the decision-making
     process. [Para 20]

                               Case Law Cited
     Managing Director, ECIL, Hyderabad and Others v. B. Karunakar
     and Others [1993] Supp. 2 SCR 576 : (1993) 4 SCC 727 – followed.

                                 List of Acts
     Central Civil Services (Classification, Control and Appeal) Rules,
     1965.

                              List of Keywords
     Service Law; Dismissal from service; Fake transfer order; Sole
     beneficiary of transfer order; Principles of Natural Justice; Hearing
     Rule (Audi Alteram Partem); Bias Rule (Nemo Judex in Causa
     Sua); Principle of Reasoned Decision, also known as Speaking
     Orders; Rule 15(2), CCS(CCS) Rules, 1965; Fair opportunity;
     Preponderance and Probability.

                             Case Arising From
     CIVIL APPELLATE JURISDICTION: Civil Appeal No. 10858 of 2024
     From the Judgment and Order dated 24.07.2018 of the High Court
     of Judicature at Bombay in WP No. 2207 of 2005

                          Appearances for Parties
     Advs. for the Appellant:
     B.H. Marlapalle, Prasenjit Keswani, Mrs. Manjula Rao, Sr. Advs.,
     Upmanyu Tewari, Avinish Kumar Saurabh, Ajit Pravin Wagh,
     Mahesh Kumar, Mrs. Akshay Kumar Sharma, Mrs. V. D. Khanna.
     Advs. for the Respondents:
     K.M Nataraj, A.S.G., Amrish Kumar, Mohd. Akhil, Balaji Srinivasan,
     B.K Satija, Siddhant Kohli, Vinayak Sharma, Ms. Satvika Thakur,
     Shubhranshu Padhi, Jay Nirupam, D. Girish Kumar, Pranav Giri,
     Ekansh Sisodia, Ms. A.M.Harsavardhini.
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                  Judgment / Order of the Supreme Court

                                  Judgment

       Augustine George Masih, J.

1.     The challenge in this appeal is to the judgment dated 24.07.2018
       passed by the Division Bench of the Bombay High Court upholding
       the judgment and order dated 29.09.2004 and 23.02.2005 passed by
       the Central Administrative Tribunal (“CAT”) in the original application
       and the review petition respectively, whereby the order of dismissal
       from service of the Appellant was sustained.
2.     The primary ground taken for challenge to the Order of the Tribunal as
       well as the High Court is that Courts failed to appreciate the violation
       of the principles of natural justice, which were not allegedly adhered
       to by the Respondents due to the non-supply of the preliminary
       Inquiry Report, where prima facie the Appellant was found to have
       violated the rules governing the service i.e. The Central Civil Services
       (Classification, Control and Appeal) Rules, 1965 [“CCS (CCA) Rules,
       1965”].
3.     The other ground which has been taken is that the chargesheet
       as served upon the Appellant is vague, which has prejudiced and
       adversely affected her defence.
4.     The next ground which has been pressed into service is the inordinate
       delay of nine years during which the inquiry proceedings continued.
       Not only this, certain documents which were sought by the Appellant
       were also not provided to her. Yet, another plea which has been taken
       is that the disciplinary authority although had returned a finding that
       the transfer order on the basis of which the Appellant was transferred
       from Kendriya Vidyalaya, Bangalore to Kendriya Vidyalaya, Mumbai
       was a fake order, but no findings were returned that the Appellant
       was in any manner involved in the issuance of the same.
5.     Yet, another plea which has been taken is that the disciplinary
       authority, despite there being no findings against the Appellant in the
       Inquiry Report as submitted, proceeded to hold the Appellant guilty
       of the charge merely because she was the beneficiary of the said
       order and that too without any evidence establishing her connection
       with procurement of the said transfer order. The violation of the
[2025] 5 S.C.R.                                                        965

                    S. Janaki Iyer v. Union of India & Ors.


     statutory rules, specially Rule 15(2) of the CCS (CCA) Rules, 1965
     stands established as this mandatory provision was not complied
     with. On this basis, prayer has been made for accepting the appeal
     by setting aside the impugned judgments and the order of dismissal.
6.   On the other hand, the Respondents have supported the judgments
     impugned as well as the order of dismissal by asserting that the
     principles of natural justice and statutory rules were duly complied
     with as there being no prejudice caused to the Appellant. The grounds
     which have been pressed into service in the present appeal, according
     to Respondents, would not lead to a situation where the impugned
     orders could be set aside. They have also asserted that the evidence,
     both documentary and oral, proves the charges against the Appellant.
     The principle which has been pressed into service is with regard to
     the standard of proof, where a preponderance of probability would
     operate to establish misconduct during the disciplinary proceedings
     vis-à-vis the proof beyond doubt as in criminal matters. That burden
     having been discharged, the findings as returned by the Inquiry Officer
     and thereafter by the disciplinary authority, passes the test as has
     been laid down in the various judgments of this Court as also the
     mandate of the Statute. Prayer has thus been made for upholding
     the impugned orders and dismissal of the appeal.
7.   Having considered the submissions made by the Counsel for the
     Appellant as well as the Counsel for the Respondents, we proceed
     to decide the present appeal.
8.   Facts in brief, which are essential for adjudication of the present
     matter, are that the Appellant was appointed as a Hindi trained
     graduate teacher on probation at Kendriya Vidyalaya Sanghathan at
     Bangalore with effect from 11.01.1989, and as a permanent teacher
     from 16.04.1992. As her husband was working in Mumbai, she sought
     her transfer from Bangalore to Mumbai or Pune. A transfer order is
     alleged to have been served on her dated 01.10.1991 wherein she
     was transferred from Kendriya Vidyalaya Sangathan, Bangalore
     to Kendriya Vidyalaya, Mumbai. The said transfer order pertains
     to twelve teachers which was issued and signed by Mr. VK Jain,
     Assistant Commissioner (Headquarters) K.V. Sanghathan, New Delhi.
     In pursuance to the said transfer order, Appellant was relieved on
     14.10.1991 and she reported at Mumbai on 18.10.1991. As the said
     transfer order had not been received by the Principal at Mumbai,
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       she was asked to wait for some time. Ultimately, she was permitted
       to join on 24.10.1991 provisionally with an undertaking to the effect
       that she would report back at Bangalore in case the transfer order
       was reversed or cancelled.
9.     The Appellant found a discrepancy in her transfer order, where she
       was mentioned as a teacher of Social Studies, whereas she was
       in fact a Hindi teacher. Accordingly, a letter was sent by her to the
       Headquarters at New Delhi seeking correction in the transfer order.
       No response thereto was received, instead an order dated 13.07.1992
       was served upon the Appellant placing her under suspension pending
       disciplinary inquiry.
10. A chargesheet dated 10.02.1993 was issued and served upon her,
    alleging that the Appellant had managed to get herself transferred
    from Kendriya Vidyalaya, Bangalore to Kendriya Vidyalaya, Bombay
    under a fake transfer order.
11. Reply to the chargesheet was filed by the Appellant on 25.06.1993
    where the said allegations were denied. The reply was found not
    satisfactory leading to initiation of disciplinary inquiry. The Inquiry
    proceedings thereafter proceeded as per the CCS (CCA), Rules 1965.
    The said proceedings continued for almost 9 years. A representation
    was submitted by the Appellant for revocation of the order of
    suspension after having exceeded the period as has been provided
    for under the CCS (CCA) Rules, 1965. The said suspension order
    was eventually revoked and the Appellant was directed to join at
    Baran, Jodhpur vide letter dated 26.03.2001. The Appellant insisted
    upon a formal transfer order to Jodhpur before proceeding and as
    is apparent, she never joined in Jodhpur. The fact remains that the
    departmental proceedings continued, and she was being paid her
    subsistence allowance regularly as per the Rules.
12. The disciplinary proceedings concluded, and a communication dated
    30.03.2001 was received by the Appellant from the disciplinary
    authority indicating that the proceedings have concluded on
    30.03.2001 and the findings were to the effect that the transfer order
    dated 01.10.1991 was fake, and since the Appellant, being the sole
    beneficiary of the transfer order why should the further proceedings
    be not held against her and suitable punishment be not imposed
    specially when all other eleven teachers mentioned in the said transfer
    order had been transferred under different orders which were found
[2025] 5 S.C.R.                                                       967

                    S. Janaki Iyer v. Union of India & Ors.


     to be genuine. The disciplinary authority, therefore has prima facie
     opined that the charges levelled against the Appellant stood true.
     The Appellant was called upon to put forth a response to the Inquiry
     report which was duly supplied along with the said communication
     dated 30.03.2001.
13. The Appellant submitted a detailed representation dated 09.04.2001
    disputing and challenging the findings of the Inquiry Officer that the
    transfer qua Appellant was fake whereas that of the others were
    genuine. The aspect with regard to the other findings was also
    challenged, taking the plea of non-compliance of the statutory rules
    as also the aspect of the conclusion drawn by the Inquiry Officer
    not connecting her with the procurement of the said transfer order
    which was alleged to be fake. The said representation was duly
    considered by the disciplinary authority but was not accepted rather
    the disciplinary authority proceeded to hold the Appellant guilty of
    the charges which she was called upon to face in the Departmental
    Inquiry and passed the punishment of dismissal from service vide
    order dated 16.11.2001.
14. The reason assigned in the said order of dismissal, apart from the fact
    that the said transfer order dated 01.10.1994 was fake, for coming to
    the conclusion with regard to the charge having been proved against
    the Appellant was that the Appellant was the sole beneficiary of the
    said order and except for her no other employee had obtained any
    undue benefit out of the said order as all the other eleven teachers
    had been transferred by various other separate orders.
15. Against this order of dismissal, the Appellant preferred a statutory
    appeal which was considered by the appellate authority and after
    affording personal hearing to the Appellant proceeded to reject the
    same vide order dated 11.02.2002.
16. This led to the institution of an Original Application before the CAT
    at Mumbai in the year 2002 which was decided vide order dated
    29.09.2004 dismissing the same upholding the order of dismissal.
    The Review Petition preferred by the Appellant was also dismissed
    on 23.02.2005 leading to the filing of the writ petition before the
    High Court of Bombay which also ended up in dismissal vide the
    impugned order dated 24.07.2018.
17. The present appeal is the outcome of the challenge to the said
    orders, judgments of the CAT and the High Court. The challenge
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       primarily is based upon the basic principle of non-compliance of the
       principles of natural justice. To press for the said assertion the first
       plea which has been taken is the vagueness of the chargesheet.
18. A perusal of the chargesheet dated 10.02.1993 would show that
    not only did it contain the charges against the Appellant but the
    same was supported by documents as well. The charge against
    the Appellant was that she managed to get herself transferred from
    Kendriya Vidyalaya, Bangalore to Kendriya Vidyalaya, Bombay
    under a fake transfer order. In this respect, the language of the said
    chargesheet in our view is very clear and specific. A common man
    on going through the same, would understand as to what were the
    charges which an employee was called upon to face and defend. The
    consequence thereof was obviously that she was the beneficiary of a
    fake transfer order. It is further apparent and is made clear from the
    fact in unambiguous terms that she was the sole beneficiary of the
    said transfer order. The plea therefore with regard to the vagueness
    of the chargesheet cannot be sustained.
19. The aspect with regard to non-supply of the copy of the Preliminary
    Inquiry Report again would not hold for long for the simple reason
    that it was never made the basis for coming to a conclusion in the
    regular Departmental Inquiry with regard to the guilt of the Appellant. It
    is an admitted fact that after the preliminary Inquiry, chargesheet was
    issued to the Appellant and thereafter a regular Departmental Inquiry
    was held where both the parties had led their respective evidence
    and on that basis the Inquiry Officer has returned his findings.
20. The principles of natural justice are founded on three fundamental
    rules that ensure fairness in legal and administrative proceedings.
    Firstly, the Hearing Rule (Audi Alteram Partem) which mandates that
    no person should be judged without being given a fair opportunity
    to present his case. Secondly, the Bias Rule (Nemo Judex in Causa
    Sua) which asserts that no one should act as a judge in its own case,
    thereby safeguarding impartiality and preventing any form of bias.
    Lastly, the principle of Reasoned Decision, also known as Speaking
    Orders, requires every decision to be supported by valid and clearly
    stated reasons to promote transparency and accountability in the
    decision-making process.
21. No prejudice having been caused because of the non-supply of the
    preliminary Inquiry Report to the Appellant, the plea of violation of the
[2025] 5 S.C.R.                                                        969

                       S. Janaki Iyer v. Union of India & Ors.


     principles of natural justice would not be available to the Appellant.
     As a matter of principle, violation of the principles of justice cannot
     be on the touchstone of technical infringement made the basis of
     setting aside the action taken by the authority against an employee
     unless it is established that grave prejudice has been caused to an
     employee because of non-supply of a particular document. Nothing
     has also come on record which would indicate that the Appellant
     had ever sought for the Preliminary Inquiry Report after the issuance
     of the chargesheet. Similar would be the position with regard to the
     other documents also which are alleged to have not been supplied
     to her as the nature and extent of disadvantage or handicap caused
     or suffered by the Appellant, in the absence of the documents, is
     missing in the departmental proceedings or the pleadings.
22. No grounds have been laid down indicating the prejudice which
    has been caused to her either during the inquiry or at the stage
    of projecting her response to the show cause notice given by the
    disciplinary authority. Mere assertion that some documents have not
    been supplied or even mentioning the said documents would not
    be enough unless the consequential prejudice which would or has
    been caused to a delinquent employee is put forth.
23. The Court is not bound to simply accept an assertion of a delinquent
    employee and proceed to question the disciplinary proceedings
    without being satisfied with regard to any prejudice having been
    caused to the employee.
24. The position in law on this aspect as has been culled out by the
    Constitution Bench of the Supreme Court in the case of Managing
    Director, ECIL, Hyderabad and Others vs. B. Karunakar and
    Others1 followed and explained thereafter by this Court expounded the
    doctrines of reasonable opportunity and natural justice to have been
    conceived and evolved not as a mechanical or a ritualistic formality,
    but as substantive principles intended to safeguard the rule of law
    and to facilitate the assertion of legitimate rights by individuals. It
    was categorically held that these principles are not to be invoked as
    mere procedural sacred words that have magical effect when said
    on every occasion, irrespective of context. The Court underscored
    the aspect as to whether prejudice has in fact been occasioned to


1   (1993) 4 SCC 727
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       an employee by the non-supply of the inquiry report which must be
       assessed with reference to the specific facts and circumstances of
       each case. Upon such assessment, if it is evident that no different
       outcome would have emerged even after the inquiry report or
       documents had been furnished, to reinstate the employee and
       grant him consequential benefits in such situation would amount to
       a distortion of justice. In other words, it would amount to conferring
       a premium upon misconduct and to stretch the doctrine of natural
       justice to an illogical and unwarranted extent. Such an expansive
       and indiscriminate application of the principle would, paradoxically,
       undermine the very concept of justice it seeks to uphold.
25. Similar is the position with regard to the plea of prolongation of the
    Inquiry for 9 years in concluding the same. The explanation as has
    been given by the Respondents with regard to the time consumed
    during the inquiry is fully justified as it had to be and actually was
    held at different places on different occasions as the matter related to
    different stations pertaining to the transfer orders of eleven teachers
    which were in question. The availability of the relevant documents
    and other aspects including the witnesses so posted etc. at different
    stations is also taken as a ground in explanation. It is not the case of
    the Appellant that she was not provided with appropriate subsistence
    allowances or facilities for attending the Inquiry proceedings which
    would have in any manner caused hindrance or difficulty to participate
    in or attend the same.
26. Mere delay during the inquiry proceedings, when it is explained with
    regard to the time taken for the inquiry to conclude and that too
    justifying the same with no prejudice having been caused, cannot
    be made the basis for vitiating the departmental proceedings.
    Inordinate or unexplained delay in the departmental proceedings
    may be a justifiable ground if tampered with prejudice having been
    established to have been caused to the delinquent employee in the
    said process for interference by the Court. In the present case, the
    same is absent and therefore the said plea of delay fails.
27. The other ground which has been pressed into service is with regard to
    non-compliance of the statutory rules in the departmental proceedings
    which were held against the Appellant. Specific reference has been
    made to Rule 15(2), CCS (CCS) Rules, 1965 which reads as follows:
            “The disciplinary authority shall forward or cause to be
            forwarded a copy of the report of the inquiry, if any, held by
[2025] 5 S.C.R.                                                            971

                    S. Janaki Iyer v. Union of India & Ors.


           the disciplinary authority or where the disciplinary authority
           is not the inquiring authority, a copy of the report of the
           inquiring authority together with its own tentative reasons
           for disagreement, if any, with the findings of inquiring
           authority on any article of charge to the Government
           servant who shall be required to submit, if he so desires,
           his written representation or submission to the disciplinary
           authority within fifteen days, irrespective of whether the
           report is favourable or not to the Government servant.”
28. A perusal of the above rule would show that in case the disciplinary
    authority disagrees with the findings returned by the inquiry authority,
    it would, along with the inquiry report forward its own tentative
    reasons for disagreement with the findings of the inquiry authority
    calling upon the delinquent employee to submit his representation/
    response to the disciplinary authority. The said procedure has been
    duly complied with and followed in the present case. The perusal of
    the inquiry report indicates that not only has the inquiring authority
    come to a definite conclusion that the transfer order was fake but
    has also concluded that the charges have been proved against her
    meaning thereby that she had managed to get herself transferred.
    Merely because the person through whom she has been able to
    procure or manage to secure the fake transfer order has not come
    in the findings of the Inquiry Officer would not lead to exoneration
    of the Appellant. There is nothing on record which would indicate
    that the Inquiry Officer had given a clean chit to the Appellant. It
    is also apparent from the records that the Appellant is the sole
    beneficiary of the said transfer order. It has come on record and in
    the Departmental Inquiry as well that eleven other teachers whose
    names find mention in the transfer order in question dated 01.10.1991
    had been transferred by different earlier orders and their transfer
    orders were not dependent solely or relatable to the order in issue.
    The plea thus of the Appellant on this count is also unsustainable.
29. As regards the submission that the findings as recorded by the
    Inquiry Officer with regard to the transfer order being fake are based
    on no evidence which could have been the only ground on which
    interference by the Court would be permissible also falls flat with an
    answer to the questionnaire served upon Shri VK Jain, the Assistant
    Commissioner in Kendriya Vidyalaya Sanghathan (Headquarters),
    New Delhi who is said to be the person under whose signatures the
    order dated 01.10.1991 was passed, when he had responded that
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       the signatures on the alleged order dated 01.10.1991 had not been
       signed by him and it was not his signature. The said transfer order
       was fake which assertion when put to test in the cross-examination in
       the departmental inquiry has not been shaken where again the said
       fact has been reiterated. When the alleged author himself denying
       the said signatures on the document and has gone to the extent
       of saying that he had not issued the said order, the requirements
       of the statutory rules in a departmental inquiry stand fulfilled. What
       has been stated above is that these are not criminal proceedings
       but departmental proceedings where the test with regard to the
       proof on the basis of evidence is different. The preponderance and
       probability being the touchstone in the departmental proceedings
       the same having been fulfilled, the plea as has been sought to be
       raised by the Appellant cannot sustain.
30. Another argument which has been raised by the Appellant is that
    the transfer order dated 01.10.1991, which had been issued with
    an intention to benefit Ms. Sandhya Jain in place of the Appellant
    at Mumbai at the behest of Assistant Commissioner Kendriya
    Vidyalaya Sanghathan, Bombay Region Mr. RK Jain appointed the
    daughter of Assistant Commissioner, Kendriya Vidyalaya Sanghathan
    (Headquarters), New Delhi. The Appellant argued that this action
    was actuated by mala fides and driven by an oblique motive, and
    therefore, the transfer order was arbitrary and not in accordance
    with law.
31. The said plea was neither taken before the CAT nor pleaded in the
    writ petition. The same, when pressed into service orally, was rejected
    by the High Court on the ground of non-pleading of the same as
    also non-impleadment of the parties against whom mala fide were
    being pressed into service. For the same reason before this Court
    the said plea, although having been sought to be projected, cannot
    be permitted. It would not be out of way to mention that here again
    in this appeal, the said persons are not parties.
32. In view of the above, there has been no violation of any statutory
    rules nor has there been violation of principles of natural justice with
    their being ample evidence to establish with regard to the transfer
    order dated 01.10.1991 being fake which fulfilled the requirements
    as have been laid down in the statutory rules as well as the law
    finalized by this Court. The Impugned Orders being in accordance
    with law do not call for any interference.
[2025] 5 S.C.R.                                               973

                     S. Janaki Iyer v. Union of India & Ors.


33. The appeal being devoid of merit stands dismissed.
34. There shall be no orders as to cost.
35. Pending application(s), if any, stand disposed of.

     Result of the case: Appeal Dismissed.




     †
         Headnotes prepared by: Ankit Gyan