JUDGMENT : The jurisdictional limits of this Court and its contours, when being called upon to consider the merits of Charge Sheets and Statements of Allegations issued against an employee by his/her employer, proposing disciplinary action; particularly when they are sought to be quashed, has been impelled for assessment in this writ petition. 2. These two writ petitions have been filed by the same individual, who is presently serving the ‘Pharmaceutical Corporation Kerala Ltd’. (‘Corporation’ for short), as its General Manager (P & A). 3. Through the first among the afore writ petitions, namely WP(C)No.15128 of 2023, the petitioner assails the Memo of Charges issued by the Corporation, imputing certain instances of misconduct and misdemeanor against him -a copy of which has been produced as Ext.P3; which is also accompanied by a Statement of Allegations dated 28.02.2023. He contends that both the Memo of Charges and the Statement of Allegations are illegal and unlawful, particularly because, through the latter, he is also ordered to be placed under suspension with effect from its date, namely 28.02.2023. 4. The petitioner says that while so, another order has been issued by the Corporation, intriguingly placing him under suspension again; and therefore, that he has been constrained to assail it through WP(C)No.2220/2023, producing the same as Ext.P2. 5. The petitioner thus calls into question the Memo of Charges and the Statement of Allegations; as also the subsequent order of suspension, as being motivated, vitiated, illegal and unconstitutional. 6. I have heard Sri.P.Ravidran, learned Senior Counsel, instructed by Smt.Lakshmi Ramdas – appearing for the petitioner in WP(C)No.2220/2023; Sri.Elvin Peter – learned counsel appearing for the petitioner in WP(C)No.15128/2023; Sri.K.Anand, learned Senior Counsel, instructed by Smt.Latha Anand – learned Standing Counsel for the “Corporation”; Sri.N.N.Sugunapalan, learned Senior Counsel, instructed by Smt.Keerthi.M. -learned counsel appearing for the 1st respondent in WP(C)No.2220/2023 and the 2nd respondent in WP(C)No.15128/2023. 7. A glance through the pleadings of these two cases which are without much of contest -would indicate that the “Corporation” initiated disciplinary action against the petitioner, on receiving certain information from two other persons -who will hereinafter be referred collectively as “Informants” -and on the basis of a letter dated 07.01.2023 issued by such persons – which, it is stated, was presented before its Board of Directors (“Board” for ease hereinafter) in its meeting of the said day. 8. 8. It transpires that the “Board” immediately resolved to cause an enquiry into the allegations impelled by the ‘informants’ in their aforementioned letter against the petitioner; and that resultantly, the impugned Memo of Charges dated 28.02.2023, accompanied by the Statement of Allegations of the same date, were issued to him. 9. Interestingly, in the Statement of Allegations, all which the “Corporation” has said is that petitioner has committed gross misconduct, as mentioned in the Memo of Charges, which will attract severe punishment; and hence that ‘it is decided to suspend him from service’ and to conduct an enquiry in such regard. 10. Presumably in furtherance of the afore, Ext.P2 in WP(C)No.2220/2013 was issued on 11.01.2023, suspending the petitioner, imputing allegations which are verbatim reproduction of the Memo of Charges earlier issued to him. 11. Sri.P.Ravindran – learned Senior Counsel for the petitioner, submitted that the actions initiated by the “Corporation” against his client are wholly malicious because, it would become limpidly discernible from various materials on record that the “Board” of the Corporation was acting in a preconceived manner, so as to trap and deracinate him. He explained that, going by the Memo of Charges and various other documents produced by the “Corporation” itself on record particularly the alleged letter of the “informants” marked as Ext.R2(a) in W.P.(C)No.2220/2023 -the gravamen of the imputations against the petitioner is that the ‘informants’ requested that they be allowed to address its “Board” on 07.01.2023, when the meeting was in session and that they were allowed to do so, during which, they allegedly disclosed that they were earlier persuaded by the petitioner to seek the information from the “Corporation” under the Right to Information Act, on the strength of the documents given to them by the former. 12. The learned Senior Counsel vehemently asserted that, a reading of Ext.R2(a) would render its contents wholly unbelievable to any reasonable person, it also containing an incredulous story woven by the ‘informants’ that, as encouraged by the petitioner, they barged into the office of the Managing Director of the “Corporation”, to accost him with certain allegations and that said Authority was pained, thus disclosing to them several important information, which then made to understand that the impression given to them by the petitioner against the “Corporation” was wrong, consequently persuading them to make the disclosure before its “Board”. 13. 13. Sri.P.Ravindran argued that, hence, by no stretch of imagination can one even fathom how the Board of a public sector undertaking could have entertained two people, whose credentials were not known and whose identities were not disclosed until that time, to address it and to give them a hand written letter, containing allegations which are wholly preposterous, implausible, dubious and mischievous, and which remains without any corroboration or substantiation, in any manner whatsoever, until now. 14. Sri.P.Ravindran thus argued that the action of the Corporation, in having suspended his client on 11.01.2023 -which was a mere four days after the alleged letter was given to the “Board” by the two ‘informants’ -would establish apodictically that this was a preconceived one, on account of certain prejudices carried by its members against his client. He concluded his submissions saying that, whatever be the nature of the allegations that may have been made against his client, it was unnecessary to have suspended him because, an enquiry could have been conducted even without such, especially when he is due to retire in less than eight months time. He added that his client has also challenged the Memo of Charges, as also the Statement of Allegations, and left it to Sri.Elvin Peter P.J. -his learned counsel in W.P.(C)No.15128/2023, to address this Court on such. 15. Sri.Elvin Peter P.J. took me extensively through the Memo of Charges issued by the Corporation against the petitioner -produced as Ext.P3 in W.P.(C)No.15128/2023 (this has also been produced as Ext.P3 in W.P.(C)No.2220/2023) -to argue that, even its close reading would render it incontestable that the accusations against his client are so vague, that no reasonable man can ever be expected to answer them, much less controvert the same. He predicated that the manner and tenor of the “allegations” are such that, certain bald statements are made and the petitioner then asked to disprove it, but recording a preconceived opinion that he cannot do so, since the conduct alleged against him by the ‘informants’ being credible. 16. Sri.Elvin Peter P.J. then took me through the Statement of Allegations to assert that, even though it is titled so, that contains no allegations whatsoever, but a virtual final conclusion that the petitioner has committed gross misconduct, deserving of attracting severe punishment; and pointed out that the reference made therein is to a complaint by the two ‘informants’. 17. 16. Sri.Elvin Peter P.J. then took me through the Statement of Allegations to assert that, even though it is titled so, that contains no allegations whatsoever, but a virtual final conclusion that the petitioner has committed gross misconduct, deserving of attracting severe punishment; and pointed out that the reference made therein is to a complaint by the two ‘informants’. 17. Sri.Elvin Peter P.J. vehemently contended that the impugned Memo of Charges and the Statement of Allegations, therefore, fall foul of the affirmative declarations of the Hon’ble Supreme Court in Government of Andhra Pradesh & Ors. v. A.Venkata Rayidu [ (2007) 1 SCC 338 ]; Anant R.Kulkarni v. Y.P. Educational Society & Ors.[AIR 2013 SCC 2098]; State of Punjab v.Khanna[ (2001) 2 SCC 330 ] and VijayShankarPandeyv.Union of India & another [ (2014) 10 SCC 589 ]. He explained that, the ratio in the afore binding precedents are conclusively to the effect that, when the charges are vague -incapable of being answered by the alleged delinquent -any enquiry edificed on it would stand vitiated; and maintained that this rings true in this case more than any other, going by the wholly amorphous nature of the imputations made against his client. 18. After submitting as afore, Sri.Elvin Peter P.J. asserted that as per his client, he is now being proceeded against solely because he had earlier brought to light certain corrupt practices of the Chairperson of the “Corporation”; thus to silence him and remove him from service in disgrace. He concluded, contending that the impugned proceedings are liable to be set aside by this Court on such ground also. 19. Sri.N.N.Sugunapalan, learned Senior Counsel appearing for the Chairperson of the Corporation -both in her official and personal capacity -submitted that the allegations against made his client by the petitioner are uncharitable, which casts aspersions on her credibility and even questions her modesty. He argued that the conduct of the petitioner in having done so is serious, leaving it to this Court to take a final decision; however, adding that every statement made by the petitioner against his client are not merely untrue, but extremely mischievous and malafide. 20. Sri.K.Anand, learned Senior Counsel appearing for the “Corporation”, began, asserting that his client has not acted with any malafides against the petitioner, because they have no reason to do so. 20. Sri.K.Anand, learned Senior Counsel appearing for the “Corporation”, began, asserting that his client has not acted with any malafides against the petitioner, because they have no reason to do so. He pointed out that, as has been averred in the counter affidavit filed by his client, the ‘informants’ met two members of the Board of the “Corporation” on 06.01.2023 and informed them that they had certain very grave information to pass on to it, thus requesting that they be granted an audience. He submitted that, on such basis, on 07.01.2023 -when the Board was in session -the ‘informants’ were heard by its members, during which, they detailed the acts of misfeasance by the petitioner and reproduced by them in a letter – copy of which is Exhibit.R2(a) in W.P.(C)No.2220/2023. The learned Senior Counsel submitted that, therefore, the “Corporation” had no other option, but to cause an enquiry because, the statements made by the ‘informants’ were so grave, that it could not have been brushed aside, especially since it appeared to mar the fair name of the Corporation, as also the reputation and credibility of the members of its Board, including its Chairperson. He contended that every applicable tenet of Administrative Law had been applied and scrupulously adhered to, before the impugned Memo of Charges and Statement of Allegations had been issued to the petitioner; and added that the petitioner was placed under suspension a month earlier than that, solely to ensure that he would not impede the disciplinary enquiry against him -he being a very senior officer of the “Corporation”. The learned Senior Counsel thus prayed that these writ petitions be dismissed. 21. The dialectical submissions of the parties being so recorded, it is ineluctable that this Court is now called upon by the rival sides to decide whether the order of suspension served on the petitioner by the “Corporation” is valid and proper in law; and further, if the actions initiated by the latter against the former, edificed on the impugned Memo of Charges and Statement of Allegations, would obtain imprimatur in law. 22. I have chosen to indite the facts involved in detail as afore, because it is necessary they are kept in close view since, on a careful assessment of it, would depend the final decision to be arrived at by this Court. 23. 22. I have chosen to indite the facts involved in detail as afore, because it is necessary they are kept in close view since, on a careful assessment of it, would depend the final decision to be arrived at by this Court. 23. Travelling with the admitted facts, the two ‘informants’ met certain Board members of the Corporation on 06.01.2023 [this is available from the counter affidavit of the “Corporation“ dated 13.02.2023 in W.P.(C)No.2220/2023] and informed them that they had certain very “grave” information against the petitioner, which they wanted to share with the “Board”. On such basis the “Board” -during their meeting on 07.01.2023 – is said to have halted their deliberations upon the matters in their agenda and to have heard the ‘informants’, who, as I have already said above, is stated to have explained their assertions in detail and then to have handed over a letter. 24. The afore letter of the informants have been made available to this Court by the Corporation as Ext.R2(a), along with their counter affidavit in W.P.(C)No.2220/2023. 25. As per Ext.R2(a) letter, the ‘informants’ say that the petitioner contacted them first and encouraged them to make an application under the Right to Information Act, seeking information qua certain affairs of the “Corporation”. They say that they did so and that they were, thereupon, again prompted by the petitioner to make further such applications, on the strength of documents which were given by him to them, which “request” was also acceded to. They then say that, subsequently, the petitioner persuaded them to make personal allegations against the Managing Director of the “Corporation” and that being so encouraged, they entered the chambers of the said Authority and accosted him, consequent to which, he disclosed to them the true affairs of the Company, which made them realise that they were being mislead by the petitioner. They appear to say that, it is in such manner, that they decided to come clean before the “Board” of the Corporation and to make a confession against the petitioner, praying that “suitable action” be taken against him, after removing him from office. 26. They appear to say that, it is in such manner, that they decided to come clean before the “Board” of the Corporation and to make a confession against the petitioner, praying that “suitable action” be taken against him, after removing him from office. 26. When one reads Ext.R2(a) very closely, it is evident that the ‘informants’ is stated to have introduced themselves to the “Board” -without any prior intimation or information -as “Activists” under the Right to Information Act, but with no substantiating or corroborating materials being produced; and then, edificed on the afore indited allegations, they required the Board to remove the petitioner from the position of General Manager and subjecting him to proceedings and punishment. 27. It would not be out of place to believe that, usually, if any such letter had been received by the Board of a responsible institution, they would have surely subjected it to necessary scrutiny and investigation, particularly when the identities and the credentials of the ‘informants’ are stated to have been not known to them until that moment. But, contrary to this, Ext.R2(g) produced by the “Corporation” – which are the minutes of the meeting of the Board held on 07.01.2023 – limpidly discloses that they decided to immediatley accept the allegations made against the petitioner by the ‘informants’ in its toto, finding it to be credible and to thus initiate an enquiry against him, after suspending him. 28. Normally, if faced with an analogous scenario, any other Company or institution may have taken cognizance of the complaint and caused necessary preliminary enquiry on it, and to proceed only if it were to find some merit in the imputations. However, in this case, even without any such, the “Board” decided, on the very same day they received Exhibit.R2(a) -and perhaps even forthwith thereafter -to suspend the petitioner and initiate disciplinary action against him. 29. One cannot gather the anxiety shown by the “Board” in initiating action against a very senior functionary of the “Corporation”, particularly when, as I have said above, the credentials of the ‘informants’, admittedly, were not known to them at that time. To add to this, in the impugned Memo of Charges, the petitioner has been informed that the ‘informants’ are ‘Public Interest Activists’, but without disclosing what is meant by such a phrase. 30. To add to this, in the impugned Memo of Charges, the petitioner has been informed that the ‘informants’ are ‘Public Interest Activists’, but without disclosing what is meant by such a phrase. 30. Further, as correctly argued by Sri.Elvin Peter P.J., the impugned Statement of Allegations, in fact, contains no allegations, but states conclusively that the petitioner has committed misconduct, which is deserving of attracting severe punishment; and in support of the same, the alleged letter of the ‘informants’ has been referred, though without being clear whether it was enclosed. 31. In the afore scenario, the petitioner has effectively been called upon to answer certain allegations made against him by two unknown persons, but who have been referred to as ‘Public Interest Activists’; and then asked to answer charges that he “i s doing all illegal activities and that whatever being carried on in the company are against the interest of the company, which statements are untrue and baseless” (sic); and further that “That you have personally summoned public interest activists viz (1) Johny Varghese (2) Joshy Kalluveetil and told them that the Managing Director and Chairman and other officers of the Company are totally corrupt and that all malpractices are adopted in the company instigated them to file petitions and complaints against the Company before various forum”(sic) 32. The primary and acme question, axiomatically, is whether the charges impelled against the petitioner are so vague that it cannot be answered by him, thus attracting the sweep of the declarations of the Hon’ble Supreme Court in Anant R. Kulkarni (supra); and if the accompanying Statement of Allegations is as forensically required. 33. To better understand the legal position involved, it is first necessary to read and assimitate the opinions of the Hon’ble Supreme Court and its declarations in the precedents that hold the field. 34. 33. To better understand the legal position involved, it is first necessary to read and assimitate the opinions of the Hon’ble Supreme Court and its declarations in the precedents that hold the field. 34. In Vijay Shankar Pandey (supra), the Honourable Supreme Court, answering the question whether the filing of a Writ Petition by an Officer of the Indian Administrative Service (IAS), alleging executive misfeasance, causing debilitating economic and security concerns for the country, would amount to a conduct inappropriate of a civil servant, held to the contrary and declared that the right to judicial remedies for redressal of either personal or public grievances is a constitutional right and that this is available even to employees of the State, since they are not members of a different or inferior class, to whom such right is not available. The Honourable Court then further held therein that, mere averments in a Writ Petition, that the Government of India lacks in discharging its constitutional obligations of establishing rule of law, cannot be said to amount to be either a failure to maintain absolute integrity and devotional duty, or of indulging in conduct unbecoming of the member of its service. 35. In Union of India and Another v. Kunisetty Sathyanarayana [ (2006) 12 SCC 28 ], dealing with the contours of the powers of Courts, qua quashing of Memos of Charges issued as a precursor to disciplinary enquiry, the Honourable Supreme Court, in paragraph 60 thereof, affirmed that it is only in rare and exceptional cases that this can be done; and that ordinarily, ‘the High Court should not interfere in such a matter’. 36. Pausing for a moment here, it is thus uncontestable that unless there are very compelling reasons, this Court would not be persuaded to quash a Charge Sheet, particularly when it is issued within the administrative powers of the employer to conduct an enquiry against its employee. 37. 36. Pausing for a moment here, it is thus uncontestable that unless there are very compelling reasons, this Court would not be persuaded to quash a Charge Sheet, particularly when it is issued within the administrative powers of the employer to conduct an enquiry against its employee. 37. Moving forward, in State of Punjab v. Khanna (supra), the Honourable Supreme Court restated the acme perspective which would be the guiding light for this Court in this case, in paragraph 37 of it, the following words: While it is true that justifiability of the charges at this stage of initiating a disciplinary proceeding cannot possibly be delved into by any court pending inquiry but it is equally well settled that in the event there is an element of malce or malafide, motive involved in the matter of issue of a charge sheet or the concerned authority is so biased that the inquiry would be a mere farcical show and the conclusions are well known then and in that event law courts are otherwise justified in interfering at the earliest stage so as to avoid the harassment and humiliation of a public official. It is not a question of shielding any misdeed that the Court would be anxious, it is the due process of law which should premate in the society and in the event of there being any affectation of such process of law that law courts ought to rise up to the occasion and the High Court in the contextual facts has delved into the issue on that score. On the basis of the findings no exception can be taken and that has been the precise reason as to why this Court dealt with the issue in so great a detail so as to examine the judicial propriety at this stage of the proceedings. 38. Further, in Anant R. Kulkarni (surpa), the Honourable Supreme Court, as early as in the year 2013, rendered it beyond argument that where the allegations in the Memos of Charges, or the Statement of Allegations are not specific, the enquiry itself would stand vitiated, notwithstanding that the delinquent raised no such defence. 38. Further, in Anant R. Kulkarni (surpa), the Honourable Supreme Court, as early as in the year 2013, rendered it beyond argument that where the allegations in the Memos of Charges, or the Statement of Allegations are not specific, the enquiry itself would stand vitiated, notwithstanding that the delinquent raised no such defence. The specific holdings of the Honourable Court is available in paragraph 10 thereof, which deserves a full reading, to facilitate which, it is extracted as under: Where the charge-sheet is accompanied by the statement of facts and the allegations are not specific in the charge-she, but are crystal clear from the statement of facts, in such a situation, as both constitute the same document, it cannot be held that as the charges were not specific, definite and clear, the enquiry stood vitiated. Thus, nowhere should a delinquent be served a charge-sheet, without providing to him, a clear specific and definite description of the charge against him. When statement of allegations are not served with the charge-sheet, the enquiry stands vitiated, as having been conducted in violation of the principles of natural justice. Evidence adduced should not be perfunctory, even if the delinquent does not take the defence of, or make a protest against that the charges are vague, that does not save the enquiry from being vitiated, for the reason that there must be fair-play in action, particularly in respect of an order involving adverse or penal consequences. What is required to be examined is whether the delinquent knew the nature of accusation. The charges should be specific, definite and giving details of the incident which formed the basis of charges and no enquiry can be sustained on vague charges. 39. The afore view of the Honourable Supreme Court was reaffirmed by it in A.Venkata Rayidu (supra), its opinion being available in paragraph 9 thereof, which is as below: We respectfully agree with the view taken by the High Court. It is a settled principle of natural justice that if any material is sought to be used in an enquiry, then copies of that material should be supplied to the party against whom such enquiry is held. In Charge I, what is mentioned is that the respondent violated the orders issued by the Government. It is a settled principle of natural justice that if any material is sought to be used in an enquiry, then copies of that material should be supplied to the party against whom such enquiry is held. In Charge I, what is mentioned is that the respondent violated the orders issued by the Government. However, no details of these orders have been mentioned in Charge I. It is well settled that a charge-sheet should not be vague but should be specific. The authority should have mentioned the date of the GO which is said to have been violated by the respondent, the number of that GO etc., but that was not done. Copies of the said GOs or directions of the Government were not even placed before the enquiry officer. Hence, Charge I was not specific and hence no finding of guilt can be fixed on the basis of that charge. Moreover, as the High Court has found, the respondent only renewed the deposit already made by his predecessors. Hence, we are of the opinion that the respondent cannot be found guilty for the offence charged. 40. The sum total and summation of the afore binding precedents is apodictically that the requirement of a delinquent being informed specifically about the imputations against him/her is inviolable; and that the accompanying Statement of Allegations should be capable of disclosing to the said person, and to make him aware and understand, what exactly has been alleged against him/her. 41. Testing the facts of this case on the afore yardstick, as I have already said above, there are virtually no allegations in the impugned Statement of Allegations, except a conclusion that the petitioner ‘had committed misconduct, deserving of severe punishment’. To make it worse, it then refers to the letter allegedly issued by the ‘informants’ to the Board, without even a mention regarding the petitioner’s alleged misconduct against the Chairperson or the Managing Director. As far as the other charges in the Memo of Charges are concerned, they relate exclusively to the statements alleged to have been made by the ‘informants’ before the Board and those contained in Ext.R2(a) letter; but without it being clear whether the same was made available to the petitioner. One can only, therefore, leave it to imagination how the petitioner could have responded to it in any manner, much less effectively. 42. One can only, therefore, leave it to imagination how the petitioner could have responded to it in any manner, much less effectively. 42. The reason for this Court to say as afore is because, the impugned Memo of Charges show that the first three charges in it are based solely on the allegations of the ‘informants’, including that ‘the petitioner is doing illegal activities against the interest of the Corporation’; that he had ‘ told the afore two ‘public interest activists’ that ‘the Managing Director and the Chairman of the Corporation are totally corrupt and that malpractices have been adopted by them (sic)’, thus instigating them to file petitions and complaints against the Corporation before various Forums; that he is ‘ spreading untrue statements regarding certain affairs of the Company;’ and that ‘ he had leaked out documents’ to the ‘informants’ ‘without the knowledge of the Managing Director or Chairman’ (sic). 43. Any reasonable person would agree that the afore could have been answered by the petitioner only by way of a monosyllabic refutation, since the Chargesheet virtually makes statements against him, without explaining on what basis they are being made; which is exacerbated for the reason that the accompanying Statement of Allegations are also completely silent about it. 44. The further ‘charges’ in the Memo of Charges refer to the alleged conduct of the petitioner after he was placed under suspension, in taking away certain files forcibly; further, that he had accosted the Chairman on 01.11.2022, speaking to her in a filthy language; and ‘disobeying the orders of the Managing Director and delaying the work by not moving the files within reasonable time’ (sic). It is not necessary for this Court to expatiate that even the afore charges are nebulous, especially with respect to the imputation that he had ‘purposefully delayed work’ and that he was not ‘moving files within reasonable time’. Quad Hoc the allegation that the petitioner accosted the Managing Director and declared that he will not obey her orders, no specifics have been mentioned in the Memo of Charges and one cannot fathom how he is expected to answer it, which is more for the admitted reason that no such accusation finds a place in the Statement of Allegations – it containing mere statements of guilt and referring only to the complaint of the ‘informants’ and nothing else. 45. 45. When the ‘Statement of Allegations’ is as afore said, it is no better than had no such been given to the petitioner. The afore precedents are luculent that the Statement of Allegations are to contain the definite description of the charges; and that when no such is offered, then that the enquiry becomes wholly untenable. As extracted in para 38 above, in Anita R. Kulkarni (supra), the inviolable declaration of law by the Honourable Supreme Court is that the charges impelled ought to be specific – it being definitely described in the Statement of Allegations, or at least in the Memo of Charges itself. As far as the case is concerned, there are virtually no allegations in the ‘Statement of Allegations’; while the charges in the ‘Memo of Charges’ are supported by no description at all, much less a ‘definite’ one. 46. That being said, the suspension of the petitioner from service solely on the basis of a concededly uncorroborated information given by the ‘informants’ in Ext.R2(a) letter – which is stated to have been handed over by them to the ‘Board’ – without any investigation of its credibility having been conducted – which factum is wholly discernible from Ext.R2(g) Minutes of its meeting on 07.01.2023, which records the decision to suspend him forthwith and to cause an enquiry – can only been seen to be rather unfortunate and uncharitable, particularly when he is occupying a very high position in the Corporation. 47. How the ‘Board’ could have acted upon the unverified inputs given to them by two individuals – with whom they had no earlier contact or acquaintance – is beyond comprehension; and this is fortified when one sees the attempt, in the Memo of Charges, as also the order of suspension of the petitioner, to make it appear that the said persons met the members of the ‘Board’ only on 07.01.2023, making a plea that they be heard with respect to certain disclosures against the petitioner, even when the counter affidavit filed by the Corporation in WP(C)No.2220/2023 present a different version, affirming that the ‘informants’ had contacted at least two members of the ‘Board’ on the earlier day, who invited them to speak at its meeting the next day. This certainly casts a long shadow on the entire proceedings. 48. This certainly casts a long shadow on the entire proceedings. 48. The afore facts are beyond the ‘Corporation’ to contest because, the counter affidavit filed by respondents 3 and 4 in WP(C)No.15128/2023 unequivocally reiterates that, on 06.01.2023, the ‘informants’ met two Board members and that they were heard by the ‘Board’ on 07.01.2023, at their request. The non-mentioning of this vital and crucial fact in the proceedings impugned in these Writ Petitions cannot be viewed to be trivial or unimportant, because, in Ext.P2 in WP(C)No.2220/2023 – through which the petitioner has been placed under suspension, what is specifically stated is that the ‘informants’ came to the venue of the ‘Board’ meeting only on 07.01.2023, without disclosing that they had met two of its members on the earlier day, or that the ‘Board’ had acceded to hear them at the latter’s request. 49. I am, therefore, left without doubt that the impugned Memo of Charges is wholly vague and non-specific, rendering it incapable for the petitioner to offer any meaningful response; which is further aggravated for the reason that the impugned ‘Statement of Allegations’ contains no allegations at all, but only findings and conclusions against the petitioner, that too, merely referring to Ext.R2(a) letter, allegedly issued by the ‘informants’ to the Board. 50. Axiomatically, the order of suspension issued against the petitioner obtain no legs to stand on as of now; and, in any event, it would be, in this Court’s firm view, impermissible to allow such an order to operate against a senior functionary of the ‘Corporation’, solely on the basis of uncorroborated and unverified information and on the contents of the alleged Ext.R2(a) letter given by two outsiders, whose credentials, or the veracity of their statements against the petitioner, are not, admittedly, confirmed through any preliminary investigation or verification. In the afore circumstances, I allow these Writ Petitions and set aside the impugned orders and proceedings. Needless to say, since I have edificed my observations and findings herein on the afore recorded specific circumstances and reasons, I deem it necessary to clarify that this Court has not entered into the merits of the allegations made by the petitioner against the Chairperson in his pleadings, finding it to be unnecessary. Needless to say, since I have edificed my observations and findings herein on the afore recorded specific circumstances and reasons, I deem it necessary to clarify that this Court has not entered into the merits of the allegations made by the petitioner against the Chairperson in his pleadings, finding it to be unnecessary. I also make it clear that this judgment will not impede the right of the ‘Corporation’ from proceeding afresh against the petitioner, if found so warranted, following due procedure; and that no other contentions, other than what has been specifically mentioned herein, have been adverted to or answered.