The Supreme Court holds that the termination of employment by non-renewal of contract due to disciplinary reasons require formal enquiry 

The appellant was employed as Assistant Project Coordinator under the Sarv Shiksha Abhiyan program on a contractual basis. She was issued two show cause notices for various allegations including dereliction of duty, negligence and indiscipline. The appellant stated that she was being harassed as she had complained about the hostel for which she was in charge. Later on, March 2013 renewal of her contract was denied due to unsatisfactory performance. The division bench of the High Court held termination to be a simple non-renewal of contract and is not stigmatic in nature. The appellant in front of the apex court argued that the termination order was stigmatic as it followed the issuance of two show cause notice that consisted of allegations of misconduct. Considering the arguments advanced from both the sides the Supreme Court in this Special Leave Petition (C) No. 11685 of 2021 set aside the order of the High Court stating that the form of an order is not its final determinant and the court can find out the real reason and true character behind terminating/removing an employee. Consequently, the appellant was ordered to be granted notional continuation in service with 50% back wages.