In a significant ruling on judicial procedure, the Supreme Court on Wednesday (February 11, 2026) set aside a Bombay High Court order that had remanded a teacher’s dismissal case to the School Tribunal without examining all the issues raised.
A bench of Justice Dipankar Datta and Justice Satish Chandra Sharma held that courts must decide all key questions involved in a case, not just one decisive point.
The judgment came in an appeal filed by Hemlata Eknath Pise against Shubham Bahu Uddeshiya Sanstha, Waddhamna and others.
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Background of the Case
Hemlata Eknath Pise, a school employee, had been dismissed from service by the management of Shubham Bahu Uddeshiya Sanstha. She challenged the dismissal before the School Tribunal at Nagpur.
In August 2019, the Tribunal ruled in her favour. It set aside the dismissal order and directed her reinstatement along with consequential benefits.
However, the management approached the Bombay High Court (Nagpur Bench). In September 2024, the High Court allowed the writ petition filed by the management and remanded the matter back to the Tribunal.
The High Court focused on a single issue - whether the Secretary of the management had proper authority under a resolution to initiate disciplinary proceedings against the teacher. Without examining other grounds, it quashed the Tribunal’s order and directed a fresh consideration.
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Pise filed a review petition, arguing that the disciplinary inquiry had violated basic principles of fairness. She contended that she was not allowed to complete cross-examination of key witnesses. According to her, the inquiry officer abruptly closed the proceedings while cross-examination of the main witness was still underway.
The High Court dismissed the review plea as well.
What the Supreme Court Examined
When the matter reached the Supreme Court, the bench closely examined whether the High Court was justified in remanding the case based on just one issue.
The judges noted that several important questions had been raised, including:
- Whether the inquiry had violated principles of natural justice - meaning fair opportunity to defend.
- Whether the Tribunal was justified in setting aside the dismissal.
- Whether the disciplinary process itself suffered from procedural flaws.
The bench observed that even if the Secretary had authority to initiate proceedings, the High Court should have also examined whether the inquiry was conducted fairly.
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“Law is pretty well-settled,” the bench remarked, “that when several issues arise for being answered by a Court… disposal ought to be preceded by recording the Court’s answers to each of such issues with reasons rather than focusing on just one decisive point.”
The court said that deciding only one issue while ignoring others was a “fundamental flaw” that vitiated the High Court’s order.
Court’s Observations on Judicial Approach
The Supreme Court stressed that addressing all issues ensures clarity and fairness for litigants. It also helps an appellate court understand the reasoning of the lower court.
By restricting itself to one technical question, the High Court, according to the bench, failed to provide a comprehensive decision.
The judges further noted that since Pise had already reached the age of retirement, reinstatement was no longer possible. Therefore, the focus before the High Court would now be on two main questions:
- Whether the Tribunal was correct in interfering with the disciplinary action.
- Whether Pise would be entitled to back wages and retirement benefits if the Tribunal’s view is upheld.
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The Final Decision
Allowing the appeals, the Supreme Court set aside both the High Court’s September 5, 2024 judgment and its September 25, 2024 review order.
The case has been remanded back to the Bombay High Court for fresh consideration. The Chief Justice of the High Court has been requested to assign the matter to an appropriate bench and ensure disposal preferably within four months.
“All questions on fact and law are kept open,” the Supreme Court clarified, leaving the parties free to argue their case before the High Court.
The appeals were accordingly allowed.
Case Title: Hemlata Eknath Pise v. Shubham Bahu Uddeshiya Sanstha, Waddhamna & Ors.
Case No.: Civil Appeal Nos. 1558–1559 of 2026
Decision Date: February 11, 2026
