Bombay High Court

Bombay High Court: Medical Officer's Challenge to Workplace Investigation Dismissed

Updated
Oct 15, 2025 10:39 PM
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Summary: Dr. Shyam Bihari, a medical officer, challenged the findings of an investigation into accusations of bad behavior at his workplace. The court supported the investigation's process and findings.

The Allegations

Dr. Shyam Bihari, who has worked since 2005 at the Nuclear Power Corporation of India Ltd. (NPCIL), faced accusations of bad behavior. A complaint was made by a colleague on behalf of his daughter, accusing Dr. Bihari of acting inappropriately during a medical check-up.

Formation of the Investigation Committee

On July 29, 2024, NPCIL set up an Internal Complaints Committee (ICC) to look into the claims. The committee included members like Dr. Sugnya Sachin Patil as the leader and others with knowledge in law and social issues.

Investigation Process

The ICC followed a clear process, giving Dr. Bihari a chance to defend himself, show evidence, and question witnesses. The investigation ended with the committee finding the accusations against Dr. Bihari to be proven.

"The ICC findings are as follows: There is not sufficient evidence to support the complainant’s allegations... However, the preponderance of possibilities is very high."

Dr. Bihari's Legal Challenge

Dr. Bihari asked the court to cancel the investigation report, arguing that the committee's makeup did not meet legal standards and was biased. He claimed there were mistakes in the process, like potential conflicts of interest among committee members.

Court's Decision

The court, led by Judges Ravindra V. Ghuge and Ashwin D. Bhobe, looked at the arguments and past decisions. They decided that the committee's makeup and processes followed the law.

"Participation of the Petitioner in the said inquiry without demur, gives an impression of the Petitioner having waived his right to object..."

Summary of the Verdict

The court rejected Dr. Bihari's request, confirming that the investigation and the ICC's findings were valid. Dr. Bihari was advised to submit his concerns to the Disciplinary Authority according to NPCIL rules.