[Ed.: In view of the recent decision in Punjab University v. Vijai Singh Lamba, (1976) 3 SCC 344 it is possible to contend that if the Disciplinary Committee adopts a rule of quorum of two out of the three members, proceedings such as above would not be improper on that count.]
Supreme Court Of India
(Apr 27, 1976)
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Case Information
Smart Summary (Beta)
Factual and Procedural Background
The provided text is an editorial note referencing quorum requirements for a Disciplinary Committee in light of a Supreme Court decision. It does not set out the underlying facts of any specific dispute or the procedural posture of a case.
Legal Issues Presented
- Whether disciplinary proceedings are valid when conducted by only two members of a three-member Disciplinary Committee, provided the Committee has formally adopted a quorum rule permitting such composition.
Table of Precedents Cited
| Precedent | Rule or Principle Cited For | Application by the Court |
|---|---|---|
| Punjab University v. Vijai Singh Lamba, (1976) 3 SCC 344 | A Disciplinary Committee’s proceedings are not improper if conducted by two members out of three, so long as the Committee has adopted a valid quorum rule to that effect. | The editorial note relies on this case to suggest that similar disciplinary proceedings would withstand challenge on the quorum ground. |
Court's Reasoning and Analysis
This excerpt is an editorial observation rather than a judicial opinion. It merely states that, in view of the cited precedent, proceedings before a three-member Disciplinary Committee should not be considered improper when only two members sit, provided a quorum rule permitting this exists. No further reasoning or analysis is supplied.
Holding and Implications
No dispositive holding was made.
The note implies that future challenges to disciplinary proceedings on quorum grounds are unlikely to succeed if the committee has expressly adopted a two-member quorum rule. No broader precedent is established beyond this implication.
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