A) ABSTRACT / HEADNOTE

The Supreme Court addressed the dismissal of a Class-IV employee, Chatrapal, from service on charges of misconduct and insubordination. The appellant alleged irregularities in his salary and filed complaints directly to higher authorities, bypassing proper channels. The disciplinary authority dismissed him, a decision upheld by the High Court. However, the Supreme Court found the inquiry report to be perverse in its findings regarding the appellant’s alleged misconduct and insubordination. The Court emphasized that sending direct representations in financial distress does not constitute major misconduct. It reinstated the appellant with all consequential benefits, underscoring the principle that findings of inquiry officers can be interfered with when they are arbitrary or perverse.

Keywords: Class-IV employee, misconduct, insubordination, dismissal, reinstatement, perverse findings, consequential benefits.

B) CASE DETAILS

i) Judgment Cause Title: Chatrapal v. The State of Uttar Pradesh & Anr.

ii) Case Number: Civil Appeal No. 2461 of 2024.

iii) Judgment Date: 15 February 2024.

iv) Court: Supreme Court of India.

v) Quorum: Justice B.R. Gavai and Justice Prashant Kumar Mishra.

vi) Author: Justice Prashant Kumar Mishra.

vii) Citation: [2024] 2 S.C.R. 348.

viii) Legal Provisions Involved: U.P. Government Servant Conduct Rules.

ix) Judgments Overruled by the Case (if any): None.

x) Case is Related to which Law Subjects: Service Law, Administrative Law.

C) INTRODUCTION AND BACKGROUND OF JUDGMENT

This case arose from the dismissal of a Class-IV employee, Chatrapal, who was employed as an Ardly in Bareilly Judgeship but later posted as a Process Server. Disputes arose over his salary and allegations of insubordination and misconduct due to direct complaints to higher authorities without following proper channels. The departmental inquiry upheld the charges, resulting in his dismissal. The High Court upheld the dismissal, prompting this appeal.

D) FACTS OF THE CASE

1. Employment Background: The appellant was appointed as Ardly in Bareilly Judgeship and later posted as a Process Server. Despite the new role, he was paid the salary of Ardly.

2. Grievances: Frustrated by the discrepancy, he made representations to the District Judge and higher officials regarding his rightful salary and allowances.

3. Allegations of Misconduct: The appellant allegedly used derogatory language in complaints and bypassed official channels by directly writing to the High Court, Chief Minister, and other officials.

4. Departmental Action: A disciplinary inquiry upheld the charges, leading to his dismissal.

5. Judicial Review: The Allahabad High Court dismissed his writ petition challenging the dismissal, affirming the findings of the inquiry report.

6. Supreme Court Appeal: The appellant challenged the findings as perverse and disproportionate, seeking relief.

E) LEGAL ISSUES RAISED

1. Validity of Inquiry Findings: Whether the inquiry officer’s findings were perverse and unsupported by evidence.
2. Proportionality of Punishment: Whether dismissal was an excessive penalty for the alleged misconduct.
3. Procedural Lapses: Whether procedural irregularities in the inquiry process caused prejudice to the appellant.

F) PETITIONER/APPELLANT’S ARGUMENTS

1. Vague Charges: The appellant contended that the charges were ambiguous and lacked specificity, particularly regarding the alleged derogatory language in complaints.

2. Absence of Evidence: The inquiry officer failed to provide concrete evidence to substantiate the allegations, rendering the findings arbitrary.

3. Disproportionate Punishment: Even if the charges were proven, the penalty of dismissal was excessive, considering his position as a Class-IV employee and financial hardship.

4. Procedural Violation: The appellant argued that he was denied access to critical documents, prejudicing his defense.

5. Precedent Cited: Reliance was placed on Sawai Singh v. State of Rajasthan [AIR 1986 SC 995] and Santosh Bakshi v. State of Punjab [AIR 2014 SC 2966], emphasizing that findings of inquiry officers must be backed by evidence.

G) RESPONDENT’S ARGUMENTS

1. Repeated Misconduct: The respondent argued that the appellant had a history of making false and derogatory allegations against superiors.

2. Proper Inquiry Conducted: The inquiry adhered to procedural requirements, and the charges were clearly established.

3. Defensive Representation: It was contended that bypassing official channels reflected insubordination, justifying the dismissal.

H) JUDGMENT

a) Ratio Decidendi

1. Perversity in Inquiry Report: The Court noted that the findings regarding derogatory language and false allegations were unsupported by evidence. The appellant’s statements were misinterpreted, rendering the inquiry report perverse.

2. Direct Representation Not Misconduct: Directly addressing grievances to higher authorities due to financial hardship does not constitute major misconduct.

3. Principles of Judicial Review: The Court reiterated that inquiry findings are subject to interference when arbitrary or perverse, relying on precedents like Union of India v. P. Gunasekaran [(2015) 2 SCC 610].

b) Obiter Dicta

The Court remarked on the disproportionate nature of dismissing a financially distressed Class-IV employee for procedural lapses like bypassing channels.

c) Guidelines Issued

1. Ensure that inquiry officers base findings strictly on evidence, avoiding misinterpretations.
2. Disciplinary authorities should assess the proportionality of penalties vis-à-vis the misconduct.

I) CONCLUSION & COMMENTS

The judgment underscores the judiciary’s role in safeguarding employees against arbitrary actions in service matters. It emphasizes proportionality in disciplinary actions, especially for economically vulnerable employees.

J) REFERENCES

a) Important Cases Referred

1. Union of India v. P. Gunasekaran, [(2015) 2 SCC 610].
2. State of Haryana v. Rattan Singh, [(1977) 2 SCC 491].
3. Chennai Metropolitan Water Supply and Sewerage Board v. T.T. Murali Babu, [(2014) 4 SCC 108].
4. Sawai Singh v. State of Rajasthan, [AIR 1986 SC 995].
5. Santosh Bakshi v. State of Punjab, [AIR 2014 SC 2966].

b) Important Statutes Referred

1. U.P. Government Servant Conduct Rules.