Facts: The petitioner, an Assistant Teacher appointed in 1995 at a school run by the Ambernath Municipal Council, was issued a show cause notice on March 17, 2018, alleging misconduct. The allegations included harassing students, non-cooperation with the administration, and breaching discipline by disobeying the Headmaster. After considering the petitioner's written explanation, the Chief Executive Officer (CEO) of the Municipal Council issued an order on July 10, 2018, imposing the punishment of "stoppage of one annual increment with permanent effect" under Rule 5(1) of the Maharashtra Civil Service (Discipline and Appeal) Rules, 1979. The respondents contended that this was a minor penalty intended to show leniency despite the serious nature of the charges.Procedural Posture: The petitioner challenged the show cause notice and the subsequent punishment order before the Bombay High Court by filing a Writ Petition under Article 226 of the Constitution of India.Issue: Does the stoppage of an annual increment with cumulative effect (permanent effect) constitute a minor penalty or a major penalty under the relevant service rules, and can such a punishment be imposed without conducting a regular departmental inquiry?Holding: The court held that the stoppage of an increment with cumulative effect constitutes a major penalty. Consequently, such a punishment cannot be imposed without following the procedure for a regular departmental inquiry as prescribed under Rule 8 of the Maharashtra Civil Service (Discipline and Appeal) Rules, 1979.Reasoning: Relying on the Supreme Court's decision in "Kulwant Singh Gill v. State of Punjab", the Court reasoned that while withholding increments "simpliciter" is a minor penalty, doing so with "cumulative effect" has a permanent impact on the employee's pay scale and future earnings. Such an order effectively reduces the employee to a lower stage in the time-scale in perpetuity, which brings it within the ambit of a major penalty. The Court noted that the CEO acted under a misconception that the penalty was minor. However, considering the petitioner was on the verge of retirement and the authority's initial intent was leniency, the Court modified the penalty to "withholding of increment simpliciter for one year without cumulative effect" rather than quashing it entirely for a fresh inquiry.