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Madras High Court· 23 July 2026

Does the power to appoint always carry with it the power to suspend or dismiss?

2026:MHC:3057
2026:MHC:3057 · W.P. (MD) No.35806 of 2025
Coram: Justice C.V.Karthikeyan · Justice R.Sakthivel
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Answer

Not where a statute provides otherwise. Although in service law the power to appoint generally means the power to suspend or dismiss as well, a statutory proviso may vest disciplinary powers in a separate authorised officer while leaving the appointing authority with administrative control and the right to move that officer for action. Such a division operates as a system of checks and balances, ensuring fairness and preventing arbitrariness.

Headnote

Constitution of India — Part IX — Tamil Nadu Panchayats Act — s.102 — s.106 — Tamil Nadu Village Panchayat Secretaries (Conditions of Service) Rules, 2023 — r.3 — Recruitment — Self-government — Constitution of India — Part IX — Tamil Nadu Panchayats Act — s.102 — Rules on service conditions are within the power — Held: Part IX empowers the State to legislate on the constitution, powers and service conditions of Panchayats so as to enable self-government; Rules prescribing only the recruiting authority, the mode of recruitment, reservation and conditions of service are within that power. (¶13, ¶17) Tamil Nadu Village Panchayat Secretaries (Conditions of Service) Rules, 2023 — r.3 — Selection by a District Level Committee — Self-government not infringed — Held further: Vesting selection in a District Level Committee while the Panchayat President remains the appointing authority regulates and standardises public employment; it neither infringes Part IX nor violates the basic structure. (¶14, ¶18) Tamil Nadu Panchayats Act — s.106 — Appointment without the power of dismissal — Checks and balances — Held further: The general rule that the power to appoint carries the power to suspend or dismiss yields to a statutory proviso; the appointing authority keeps administrative control and may move the authorised officer, which guards against arbitrariness. (¶15) Recruitment — Wide public notice — Two newspapers, one in the vernacular — Held further: A post must be advertised in at least two newspapers, one in the vernacular, besides calling for names from the employment exchange; an appointment made without such notice is void ab initio. Petition dismissed. (¶20, ¶21, ¶25)

In the Court's own words
Paragraph 15That apart, while in general, in service law, power to appoint means power to suspend or dismiss as well, in the case of Panchayat Secretaries, this general principle would not apply in view of the statutory provision under the proviso to Section 106 of the T.N.P.A. Act, as per which, even though the Panchayat Presidents are the appointing authorities for Panchayat Secretaries, they do not hold the powers to dismiss, suspend or take disciplinary actions and such powers are vested with the authorised officer contemplated thereunder. Nonetheless, the Panchayat President would continue to exercise administrative control over the Panchayat Secretary and he/she can very well raise their concerns / complaints against the Panchayat Secretary before the authorised officer for appropriate action. Given that Panchayat Secretary remains under the administrative control of the Panchayat President, which includes sanctioning of monetary increments, this provision provides a check and balance mechanism. A system of checks and balances ensures fairness and helps prevent arbitrariness, which would only promote the accountability, transparency and efficiency of the Panchayat administration and in no way threaten its power of self-government.
Acts & Sections
Part IX Constitution of Indias.102 Tamil Nadu Panchayats Acts.106 Tamil Nadu Panchayats Actr.3 Tamil Nadu Village Panchayat Secretaries (Conditions of Service) Rules, 2023Tamil Nadu Government Servants (Conditions of Service) Act, 2016

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Also decided in this judgment
Does prescribing the mode of recruitment for a Panchayat's own staff infringe the Panchayat's status as an institution of self-government?Can residence in a local area be imposed as a condition for appointment to a local-body post?How must a public post be advertised before it is filled?
Plain-language answer prepared by the LexStreak Editorial Desk — verify against the judgment. Source: Madras High Court. Corrections