Published on: December 07, 2023 at 10:22 IST
The Supreme Court ordered on the legitimacy of disciplinary actions when predicated on identical evidence, witnesses, and circumstances as a criminal case resulting in acquittal.
The court emphasized that a mere acquittal in a criminal court does not automatically entitle the employee to claim benefits, such as reinstatement. Nevertheless, if the charges in both the departmental inquiry and the criminal court are similar, and the evidence, witnesses, and circumstances align, the court, during judicial review, can intervene under specific conditions.
The bench, comprising Justice J.K. Maheshwari and Justice K.V. Viswanathan, stated that if the court determines that the criminal acquittal resulted from a thorough consideration of the prosecution’s evidence and a failure to substantiate the charges, it can rectify the situation in certain circumstances.
The court is empowered to exercise discretion and provide relief if maintaining the findings in the disciplinary proceedings would be deemed unjust, unfair, or oppressive. The court stressed that each case must be evaluated based on its unique facts.
The Supreme Court also underscored the obligation of the court during judicial review to scrutinize the substance of a judgment rather than relying solely on the expressions used, cautioning against treating phrases like “benefit of doubt” and “honorably acquitted” as magical incantations.
The case in question involved a constable from the Rajasthan Armed Constabulary in Jodhpur, appointed in 1991, who faced a criminal trial and a departmental inquiry in 2022 for allegedly altering his date of birth in official documents.
Although the trial court convicted him, the appellate judge later acquitted him. Despite this, the disciplinary authority found the charges proven and terminated his service.
Upon the appellant’s challenge before the High Court, which rejected relief citing differing standards of proof in criminal and departmental proceedings, the matter reached the Apex Court.
The Supreme Court reiterated that the writ court’s authority to review disciplinary decisions is confined to examining the legitimacy of the decision-making process and emphasized that mere criminal acquittal does not warrant automatic reinstatement.
However, in this case, the Supreme Court concluded that the Disciplinary Authority had drawn inferences about the charges without considering material evidence.
The court found, after a comprehensive review of the trial court’s judgment, that the appellant was acquitted due to the prosecution’s failure to prove the charges. It emphasized that during judicial review, the court must delve into the substance of the judgment rather than merely relying on its form of expression.
Consequently, the Supreme Court determined that the disciplinary proceedings were flawed and warranted annulment. It asserted that if disciplinary findings are reached by ignoring pertinent material, the court during judicial review has the authority to intervene.
Accepting the appellant’s explanation that overwriting in the application form was a correction of an inadvertent error, the court directed the appellant’s reinstatement with all associated benefits, including seniority, notional promotions, and salary fitment.
Case Title: Ram Lal V. State of Rajasthan