Supreme Court Reinstates Dismissed Employee, Citing Perverse Findings: Chatrapal vs. State of Uttar Pradesh (2024)

Date of the Judgment: February 15, 2024
Citation: 2024 INSC 115
Judges: B.R. Gavai, J., Prashant Kumar Mishra, J.
Can a disciplinary inquiry be upheld if its findings are based on incorrect facts? The Supreme Court of India recently addressed this question in a case concerning the dismissal of a Class IV employee. The Court found that the inquiry against the employee was based on a perverse finding and reinstated him with all consequential benefits. This judgment highlights the importance of factual accuracy and fairness in departmental inquiries. The judgment was authored by Justice Prashant Kumar Mishra, with Justice B.R. Gavai concurring.

Case Background

The appellant, Chatrapal, was permanently appointed as an Ardly (Class IV post) in the Bareilly Judgeship. On August 24, 2001, he was transferred and posted as a Process Server in the Nazarat of the outlying court of Baheri, District Bareilly. He joined the new post on August 31, 2001, but continued to receive the salary of an Ardly.

On January 20, 2003, Chatrapal requested the District Judge to pay him the salary due to a Process Server. A report from the Munsarim confirmed that he had been working as a Process Server since August 31, 2001. Following this, Chatrapal alleged that the Central Nazir harassed him and demanded a bribe to settle his dues. On June 5, 2003, Chatrapal wrote to the Janapad Nyaayaadeesh, stating that he was not receiving the allowances for Process Servers at outlying courts and that the Central Nazir demanded a bribe. The District Judge sought an explanation from the Central Nazir, who admitted the salary error but denied demanding a bribe.

Subsequently, on June 21, 2003, the District Judge suspended Chatrapal and initiated a departmental inquiry. The inquiry charged him with using inappropriate language and making false allegations against officials and for sending communications to higher authorities without proper channels. The inquiry concluded that the charges were established, and Chatrapal was dismissed on April 30, 2007. His appeal was dismissed by the High Court on September 19, 2007, and his writ petition was also dismissed, leading to the present appeal before the Supreme Court.

Timeline:

Course of Proceedings

The District Judge, Bareilly, initiated a departmental inquiry against Chatrapal, leading to his dismissal on April 30, 2007. The Administrative Judge of the High Court of Allahabad dismissed his appeal on September 19, 2007. Chatrapal then filed a Writ Petition (C) No. 297 of 2008 before the High Court, which was also dismissed. Consequently, he appealed to the Supreme Court.

Legal Framework

The case primarily involves the interpretation of principles governing departmental inquiries and the scope of judicial review of such inquiries. The judgment refers to the U.P. Government Servant Conduct Rules, particularly Rule 3, which deals with the conduct of government servants. The Supreme Court also considered its previous judgments on the standards of evidence and review in departmental proceedings.

Arguments

Appellant’s Arguments:

• The first charge against the appellant was vague, as the Inquiry Officer did not specify which allegations in the letter dated 05.06.2003 were false.
• Even if the language used in the complaint was a breach of Rule 3 of the U.P. Government Servant Conduct Rules, the punishment of dismissal was disproportionate.
• The appellant was not provided with copies of crucial documents, including proposed evidence, which prejudiced his defense.
• The findings of guilt by the Inquiry Officer were perverse.

The appellant relied on the decisions of the Supreme Court in Sawai Singh vs. State of Rajasthan and Santosh Bakshi vs. State of Punjab.

Respondent’s Arguments:

• The appellant was a habitual offender who made false allegations against senior officers, including the District Judge.
• The charges against the appellant were specific and not vague.

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame issues in a separate section. However, the following issues were discernible from the judgment:

1. Whether the findings of the Inquiry Officer were based on a correct appreciation of facts and evidence.
2. Whether the punishment of dismissal was proportionate to the charges against the appellant.
3. Whether the inquiry was conducted in accordance with principles of natural justice.

Treatment of the Issue by the Court

The following table demonstrates as to how the Court decided the issues

Authorities

The Supreme Court considered the following authorities:

Judgment

The Supreme Court allowed the appeal, setting aside the High Court’s judgment and the order of dismissal. The Court ordered the reinstatement of Chatrapal with all consequential benefits. The Court’s reasoning was based on the following:

How each authority was viewed by the Court?

✓ Union of India vs. P. Gunasekaran (2015) 2 SCC 610*: The Court followed this authority to reiterate the principles of judicial review in departmental proceedings, emphasizing that High Courts should not act as appellate authorities and should not re-appreciate evidence.

✓ State of Haryana vs. Rattan Singh (1977) 2 SCC 491*: The Court followed this authority to highlight the principle that domestic inquiries should be based on logical and probative material, and that perversity or arbitrariness vitiates the conclusions.

✓ Chennai Metropolitan Water Supply and Sewerage Board vs. T.T. Murali Babu (2014) 4 SCC 108*: The Court followed this authority to reiterate the principles of judicial review in departmental proceedings.

The Court noted that the Inquiry Officer’s finding that the appellant made a false statement about meeting the Central Nazir was incorrect. The Court observed that the appellant had stated in his letter dated 05.06.2003 that he met the Janapad Nyaayaadeesh multiple times, not the Central Nazir. The Court also noted that the appellant did not make any caste-based allegations against the District Judge. Instead, he stated that the Central Nazir told him that the District Judge had made such remarks. The Court found that the Central Nazir had not specifically denied making such a statement.

Regarding the second charge of sending representations directly to higher authorities, the Court held that it was not a major misconduct warranting termination. The Court also noted that other employees had sent representations directly to higher authorities without any action being taken against them.

The Court emphasized that while findings of the Inquiry Officer should not be interfered with ordinarily, they could be if the findings are perverse.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the following factors:

• The perverse finding of the Inquiry Officer regarding the appellant’s meeting with the Central Nazir.
• The lack of specific denial by the Central Nazir regarding the caste-based remarks.
• The disproportionate nature of the punishment for the second charge of sending representations through improper channels.
• The fact that the appellant was a Class IV employee.

The Court’s reasoning was based on a thorough examination of the factual record and the legal principles governing departmental inquiries. The Court emphasized the importance of fairness and accuracy in such proceedings. The Court’s decision was not merely a technical correction but a substantive intervention to ensure justice for the appellant.

The Court’s reasoning was based on the following:

• “The finding of the Inquiry Officer that the appellant’s statement in his application dated 05.06.2003 that he met the Central Nazir number of times between 24.08.2001 to 15.01.2003 is not reflected in appellant’s representation.”
• “Insofar as the allegation that the appellant made false allegations of discrimination on caste basis, it is significant to notice that the appellant himself has not made any such allegation in his letter dated 05.06.2003.”
• “Even otherwise, the appellant has cited examples of other employees of the District Court, Bareilly who have sent representations directly to the superiors, but no action has been taken against them.”

There were no minority opinions in this case.

Key Takeaways

• Departmental inquiries must be based on accurate facts and evidence.
• Punishments in disciplinary proceedings must be proportionate to the charges.
• Perverse findings in departmental inquiries can be interfered with by appellate authorities and writ courts.
• Class IV employees should not be subjected to harsh punishments for minor infractions.

Directions

The Supreme Court directed the reinstatement of the appellant, Chatrapal, with all consequential benefits.

Development of Law

The ratio decidendi of this case is that findings in departmental inquiries must be based on a correct appreciation of facts and evidence. This case reinforces the principle that perverse findings can be interfered with by appellate authorities and writ courts. The Supreme Court reiterated the principles of judicial review in departmental proceedings as laid down in Union of India vs. P. Gunasekaran and State of Haryana vs. Rattan Singh.

Conclusion

The Supreme Court’s judgment in Chatrapal vs. State of Uttar Pradesh is a significant reminder of the need for fairness and accuracy in departmental inquiries. The Court’s decision to reinstate the appellant underscores the importance of ensuring that disciplinary proceedings are based on sound reasoning and factual accuracy. The Court’s intervention highlights the role of the judiciary in safeguarding the rights of employees against arbitrary and disproportionate actions by employers.