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Rajasthan State Roadways Transport Corporation v. Paramjeet Singh

Civil Appeal · 2019 INSC 621Decided 3 May 2019
Civil Appeal No. 4593 of 2019
Dr. Justice D.Y. Chandrachud · Justice Hemant Gupta

Background

The respondent was engaged as a bus conductor on a one-year (or shorter, if the driver shortage was resolved sooner) contractual basis by the appellant Corporation. The contract expressly allowed the Corporation to terminate the appointment at any time without notice, and also provided specific consequences if a passenger were found travelling without a ticket. The Corporation terminated the respondent's services after about 14 months, and he successfully challenged the termination before a Single Judge of the Rajasthan High Court (later upheld by a Division Bench) solely on the ground that it breached principles of natural justice.

Decision Breakdown

The Supreme Court held that the High Court had erred, because the appointment was purely contractual with an express clause permitting termination without notice at any time, so no principle of natural justice (such as a hearing before termination) was owed to the respondent in these circumstances. It distinguished the precedent the Single Judge had relied upon, noting that case involved removal for a specific misconduct charge (bribery), which required due process, unlike this case, which was a plain exercise of a contractual termination-without-notice clause. The Court allowed the appeal, set aside the High Court's judgment, and dismissed the respondent's writ petition, with no order as to costs.

Lesson Learnt

Where a contract of temporary/contractual employment expressly allows termination without notice, courts will not import a natural-justice hearing requirement into a termination that is simply a straightforward exercise of that contractual term: natural justice protections apply more strongly where termination is linked to an allegation of misconduct, not a no-fault contractual exit.

Official source (sci.gov.in)View Judgment (PDF)

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