The Central Administrative Tribunal (CAT), Principal Bench, New Delhi, has stepped in to halt disciplinary proceedings against senior IRS officer Sameer Dnyandev Wankhede, ruling that the charge memorandum issued to him could not proceed at this stage. The tribunal delivered its order after an intense hearing involving long-standing disputes over a preliminary inquiry and its later use in departmental action.
Background of the Case
Sameer Wankhede, a 2008-batch Indian Revenue Service officer, is currently posted as Additional Commissioner under the Department of Revenue. Earlier, he served as Zonal Director of the Narcotics Control Bureau (NCB), Mumbai. During his tenure, several high-profile drug cases were investigated, including the Cordelia Cruise case of 2021.
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Following allegations of procedural lapses in that case, a Special Enquiry Team (SET) was constituted by the NCB. The SET submitted a report in June 2022. Wankhede challenged the report before the CAT, arguing that the inquiry was unfair because a senior officer who had supervised the investigation was also part of the enquiry process.
In earlier rounds, the tribunal and later the Delhi High Court clarified a key point: findings of a preliminary enquiry like the SET report could not be used to indict an officer in a regular departmental enquiry.
Despite these directions, the Department of Revenue issued a charge memorandum in August 2025, alleging that Wankhede had improperly sought confidential information and attempted to influence the course of investigation after being relieved from the NCB.
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What the Tribunal Examined
The CAT examined whether the charge memorandum was legally sustainable, especially when it appeared to rely on material that had already been the subject of judicial scrutiny. The bench also noted that some of the evidence cited in the charges was already under consideration before the Bombay High Court in a pending criminal writ petition, where interim protection had been granted to Wankhede.
The tribunal recalled that earlier orders had clearly restrained authorities from relying on evidence collected during the SET’s preliminary inquiry for any future disciplinary action.
Court’s Observations
The bench, headed by Justice Ranjit More with Member (Administrative) Rajinder Kashyap, stressed the settled legal position on preliminary inquiries. It observed that courts have consistently held that such inquiries are only fact-finding exercises and cannot form the sole basis for disciplinary punishment.
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“The findings and evidence of a preliminary enquiry cannot be straightaway used to indict an officer in departmental proceedings,” the tribunal noted, reiterating what had already been affirmed by the Delhi High Court in connected litigation.
The CAT also took note of the fact that the issues raised in the charge memorandum overlapped with matters pending before the Bombay High Court, where interim relief was operating in favour of the officer.
Decision
In its final order pronounced on 19 January 2026, the Central Administrative Tribunal stayed further proceedings arising from the charge memorandum dated 18 August 2025. The tribunal restrained the authorities from continuing with the departmental enquiry against Sameer Wankhede until the legal issues already pending before constitutional courts are resolved.
The original application was thus allowed to the extent of granting relief against the impugned charge memorandum, bringing temporary closure to the disciplinary action initiated against the officer
Case Title: Sameer Dnyandev Wankhede vs Union of India & Ors.
Case Number: O.A. No. 3258 of 2025
