Dismissed¶35

S. Karpagam v. The Tamil Nadu State Information Commission

Madras HC9 Feb 2026WA(MD)/103/2026

Case brief

AI extract

What is this about?

Departmental proceedings initiation by Chief Information Commissioner treated as commencement; Public Information Officer status at relevant point of time is a question of fact for the inquiry, not writ jurisdiction; Tamil Nadu State Information Commission; Deputy Inspector General of Registration, Ramanathapuram Zone; Registration Department staff cum Information Officer; writ appeal under Clause 15 Letters Patent dismissed; W.P.(MD)No.29346 of 2025 upheld in effect; Madurai Bench of Madras High Court; no costs.

What did the court decide?

The communication of the Chief Information Commissioner to the Deputy Inspector General of Registration to initiate departmental proceeding against the writ petitioner for the alleged dereliction of duty is the commencement of the proceedings. ¶31

S. Karpagam Vs The Tamil Nadu State Information Commission — Madras HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Dismissed

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Issue for consideration

Whether the appellant, who contended that she was not the Public Information Officer at the relevant point of time, could obtain quashing of the initiation of departmental proceedings in writ jurisdiction, or whether that factual question must be determined in the course of the departmental proceedings. +1 more

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Court's answer

Whether the appellant was the Information Officer at the relevant point of time and other material facts can be tested only in the course of the departmental proceedings; the High Court cannot examine these factual aspects.

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Ratio / Principle

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Detailed headnote1 paragraphs

Writ Appeal under Clause 15 of the Letters Patent (W.A.(MD)No.103 of 2026, Madurai Bench of Madras High Court, decided 09.02.2026) against dismissal of W.P.(MD)No.29346 of 2025 (decided 10.12.2025). Appellant S. Karpagam, a staff member of the Registration Department who was also an Information Officer, challenged the communication of the Chief Information Commissioner to the Deputy Inspector General of Registration, Ramanathapuram Zone, directing initiation of departmental proceedings against her for alleged dereliction of duty, contending she was not the Public Information Officer at the relevant point of time and that no departmental proceedings had so far been initiated. The learned Single Judge had declined interference, holding that departmental proceedings were already initiated and underway and that questions of fact were determinable in the inquiry. The Division Bench (Dr. G. Jayachandran, J. and K.K. Ramakrishnan, J.; judgment by Dr. G. Jayachandran, J.) held that the Chief Information Commissioner's communication itself constitutes the commencement of the departmental proceedings, and that whether the appellant was the Information Officer at the relevant point of time is a material fact that can be tested only in the course of the departmental proceedings, which the writ Court cannot examine. Writ appeal dismissed; connected miscellaneous petition (C.M.P.(MD)No.1075 of 2026) closed; no order as to costs.

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W.A.(MD)No.103 of 2026

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BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT

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DATED: 09.02.2026

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CORAM:

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THE HONOURABLE DR.JUSTICE G. JAYACHANDRAN AND

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THE HONOURABLE MR.JUSTICE K.K. RAMAKRISHNAN

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W.A.(MD)No.103 of 2026 and C.M.P.(MD)No.1075 of 2026

S.Karpagam

... Appellant

Vs.

1.The Tamil Nadu State Information Commission, Represented by the Assistant Registrar, Block No.19, Government Farm Village, Pernpet, Nandanam, Chennai-600 035.

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2.The Deputy Inspector General of Registration, Registration Department, Ramanathapuram Zone, Vandikkara Street, Ramanathapuram, Ramanathapuram District.

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3.Venkataraman Parthasarathy

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4.Balaji ... Respondents

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PRAYER:- Writ Appeal – filed under Clause 15 of the Letters Patent, to set aside the order in W.P.(MD)No.29346 of 2025 dated 10.12.2025 on the file of this Court.

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https://www.mhc.tn.gov.in/judis

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W.A.(MD)No.103 of 2026

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For Appellant : Mr.P.Prabakaran For Respondents : Mr.A.Kannan (R2) Additional Government Pleader

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JUDGMENT

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(Judgment of the Court was delivered by DR.G.JAYACHANDRAN, J.)

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Being aggrieved by the dismissal of the writ petition with the following observations, this writ appeal has been filed:

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“5. Considering the facts and circumstances of the case and since the departmental proceedings have already been initiated and are underway, this Court is of the view that the petitioner can raise all his contentions during the course of the inquiry. Questions of fact, such as whether the petitioner was responsible for not furnishing the information or any other defense taken by the petitioner, can only be determined during the inquiry proceedings. In view of the same, no prima facie error is found in the impugned order.”

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2.The learned counsel for the writ petitioner/appellant submits

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that at the relevant point of time, the appellant was not the Public Information Officer and therefore, the order issued by the Chief

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2/5

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https://www.mhc.tn.gov.in/judis

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W.A.(MD)No.103 of 2026

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Information Commissioner to initiate departmental proceedings as against the appellant, is liable to be quashed. However, the learned Single Judge on considering the submission, has held that since departmental proceedings has already been initiated, the writ petitioner has to seek redressal, by participating in the departmental proceedings.

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3.The learned counsel for the appellant/writ petitioner submits that so far, no departmental proceedings has been initiated.

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4.We find that the communication of the Chief Information Commissioner to the Deputy Inspector General of registration to initiate departmental proceeding against the writ petitioner for the alleged dereliction of duty, is the commencement of the proceedings. The appellant being not only a staff in the Registration Department, but also being an Information Officer, it is for her to make her submission as to whether at the relevant point of time she was the Information Officer or not, in the course of the departmental proceedings. These material facts can be tested only in the course of departmental proceedings. This Court cannot examine the factual aspects.

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https://www.mhc.tn.gov.in/judis

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W.A.(MD)No.103 of 2026

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5.Accordingly, this writ appeal is dismissed. Consequently,

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connected miscellaneous petition is closed. There shall be no order as to costs.

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[G.J., J.] & [K.K.R.K., J.] 09.02.2026

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Index :Yes/No Internet :Yes ta

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The Deputy Inspector General of Registration, Registration Department, Ramanathapuram Zone, Vandikkara Street, Ramanathapuram, Ramanathapuram District.

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4/5

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https://www.mhc.tn.gov.in/judis

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W.A.(MD)No.103 of 2026

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DR.G. JAYACHANDRAN, J. AND K.K. RAMAKRISHNAN, J.

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W.A.(MD)No.103 of 2026

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