On 1 October 1993, a five-judge Constitution Bench held that a delinquent employee is entitled to a copy of the inquiry officer's report before the disciplinary authority decides — but tempered the remedy with a prejudice test, making non-supply void only where the employee shows prejudice.
On 11 July 1985, a five-judge Constitution Bench upheld the second proviso to Article 311(2) — the three situations in which a civil servant may be dismissed without the constitutional inquiry — while holding the recorded satisfaction reviewable by courts for relevance and bona fides.