On 19 December 2008, the Supreme Court held that a departmental enquiry finding cannot rest on the inquiry officer's ipse dixit, surmise or conjecture — that suspicion is never a substitute for legal proof, and that disciplinary orders carrying civil consequences must be supported by recorded reasons.
On 1 May 2001, a five-judge Constitution Bench of the Supreme Court affirmed the Shambhu Nath Goyal threshold-pleading rule — management must, at the first opportunity in its written statement before the Tribunal, reserve the right to lead fresh evidence in the event the domestic enquiry is found invalid.