Three-Judge Bench in Posts and Telegraphs Board v. C.S.N. Murthy, (1992) 2 SCC 317, after Baikuntha Nath v. Chief District Medical Officer, Baripada, (1992) 2 SCC 299, held, Courts would not interfere with exercise of power of compulsory retirement if arrived bona fide-ly and on basis of material available on record.
Three-Judge Bench in Union of India v. Dulal Dutt, (1993) 2 SCC 179 held, an order of compulsory retirement is not an order of punishment. It is a prerogative of Government and has to be passed on subjective satisfaction of Government.
Ram Murti Yadav v. State of Uttar Pradesh, (2020) 1 SCC 801 held, Principles of Natural Justice have no application in a case of compulsory retirement. Scope for judicial review of an order of compulsory retirement based on subjective satisfaction of employer is extremely narrow and restricted. Only if it is found to be based on arbitrary or capricious grounds, vitiated by mala fides, overlooking relevant materials, could there be limited scope for interference.
– Hon’ble Justice Hemant Gupta, Central Industrial Security Force v. Om Prakash, [Civil Appeal No. 5428 of 2012].