In Brief
A workman at the Nuclear Fuel Complex–Hyderabad was charged with possessing a fake qualification certificate. NFC initiated disciplinary proceedings under the Central Civil Services (Classification, Control and Appeal) Rules, 1965, but the workman argued that proceedings must follow certified Standing Orders notified for NFC in 1973 under the Industrial Employment (Standing Orders) Act, 1946. The High Court quashed the proceedings, upholding the primacy of Standing Orders. The Supreme Court dismissed the Union's appeal, holding that certified Standing Orders—a special enactment protecting workmen—prevail over general service rules. Any modification requires formal procedure under Section 10 of the 1946 Act, which NFC failed to follow. Benefits under general rules cannot override procedural protections in Standing Orders.
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