A) ABSTRACT / HEADNOTE

This case revolves around the performance appraisal system of IAS officers under the All India Services (Performance Appraisal Report) Rules, 2007 (PAR Rules). The issue concerns the downgrading of a senior officer’s appraisal score by the Accepting Authority and the extent of judicial interference in administrative matters. The Supreme Court upheld the principle of administrative expertise, setting aside the High Court’s judgment that had overruled the CAT decision favoring the State of Haryana. The Court reinforced the discretion of administrative authorities in performance evaluations, emphasizing adherence to timelines and procedural rules, and limited judicial overreach in technical or specialized domains.

Keywords: IAS Officer, Judicial Overreach, Performance Appraisal, Administrative Expertise, Article 226.

B) CASE DETAILS

i) Judgment Cause Title
The State of Haryana v. Ashok Khemka & Anr.

ii) Case Number
Civil Appeal No. 3959 of 2024

iii) Judgment Date
March 11, 2024

iv) Court
Supreme Court of India

v) Quorum
Justice Vikram Nath and Justice Satish Chandra Sharma

vi) Author
Justice Satish Chandra Sharma

vii) Citation
[2024] 3 S.C.R. 393 : 2024 INSC 190

viii) Legal Provisions Involved

1. Constitution of India – Article 226
2. All India Services (Performance Appraisal Report) Rules, 2007 – Rules 5(1) and 9(7B)

ix) Judgments Overruled by the Case (if any)
High Court of Punjab & Haryana in CWP No. 317 of 2019

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

C) INTRODUCTION AND BACKGROUND OF JUDGMENT

This case stems from a dispute over the grading of an IAS officer’s Performance Appraisal Report (PAR) by different authorities under the PAR Rules, 2007. The High Court had intervened in the administrative decision-making process, which was later challenged by the State of Haryana. The Supreme Court evaluated whether the High Court’s interference was justified, considering the scope of Article 226 and the principles of administrative autonomy.

D) FACTS OF THE CASE

1. Timeline of Events:

   • Respondent No. 1, an IAS officer, submitted his self-appraisal form for the period April 8, 2016, to March 31, 2017.
   • The Chief Secretary of Haryana (Reporting Authority) awarded an overall grade of 8.22.
   • The Health Minister of Haryana (Reviewing Authority) upgraded the grade to 9.92.
   • The Chief Minister of Haryana (Accepting Authority) downgraded the grade to 9.

2. Procedural Developments:

   • Dissatisfied, Respondent No. 1 filed a representation under Rule 9(2) of the PAR Rules.
   • Upon inaction on the representation, he approached the Central Administrative Tribunal (CAT), which upheld the Accepting Authority’s decision.
   • The High Court overruled the CAT’s decision, restoring the Reviewing Authority’s grade.

3. Supreme Court Involvement:

   • The State of Haryana appealed the High Court’s decision, arguing that administrative expertise should not be second-guessed by the judiciary unless clear mala fides or prejudice were proven.

E) LEGAL ISSUES RAISED

1. Whether the High Court was justified in interfering with the CAT’s decision under Article 226 of the Constitution.
2. Whether the downgrading of the performance appraisal score complied with the mandatory provisions of the PAR Rules.
3. Implications of non-adherence to prescribed timelines under the PAR Rules.

F) PETITIONER/APPELLANT’S ARGUMENTS

1. Procedural Compliance:
   The State of Haryana contended that the Accepting Authority met the mandatory timelines under Rule 5(1) of the PAR Rules, and the score alteration was procedurally sound.

2. Administrative Discretion:
   It was argued that the evaluation of IAS officers is a specialized administrative function requiring expertise. The judiciary lacks the requisite domain knowledge to challenge such decisions without evidence of mala fides.

3. No Prejudice to Respondent No. 1:
   The Accepting Authority’s score of 9 still fell within the ‘outstanding’ category, ensuring no adverse impact on career progression.

4. Reliance on Judicial Precedents:
   Cited Caretel Infotech Ltd. v. Hindustan Petroleum Corporation Ltd. (2019) and State of Jharkhand v. Linde India Ltd. (2022), emphasizing judicial restraint in administrative matters.

G) RESPONDENT’S ARGUMENTS

1. Violation of Timelines:
   Respondent No. 1 asserted that the Accepting Authority contravened the prescribed timelines under the PAR Rules, rendering its evaluation invalid.

2. Arbitrary Downgrading:
   The Accepting Authority allegedly failed to provide cogent reasons for downgrading the grade, contravening principles laid down in Dev Dutt v. Union of India (2008).

3. Impact on Career:
   The downgraded score was prejudicial, especially given the respondent’s nearing superannuation.

H) JUDGMENT

a. RATIO DECIDENDI

1. Mandatory vs. Directory Provisions:
   The Court distinguished between timelines that are mandatory and directory, holding that non-adherence to directory timelines does not invalidate the appraisal.

2. Judicial Restraint in Administrative Matters:
   Emphasized the limited scope of judicial review in administrative decisions involving specialized evaluation.

3. Adherence to Rule 5(1):
   Held that the Accepting Authority complied with Rule 5(1) and awarded grades in line with established procedures.

b. OBITER DICTA

1. The judiciary must respect the expertise of administrative authorities unless mala fides or procedural lapses are evident.

c. GUIDELINES

1. Avoid judicial intervention in appraisal systems absent evidence of arbitrariness or procedural breaches.
2. Adhere to prescribed procedural safeguards while respecting administrative timelines.

I) CONCLUSION & COMMENTS

This judgment reinforces the boundaries between judicial review and administrative autonomy, particularly in performance evaluations. The Court’s reliance on procedural adherence and expertise-based discretion establishes a precedent limiting judicial overreach in administrative matters.

J) REFERENCES

Important Cases Referred

1. Dev Dutt v. Union of India (2008) 8 SCC 725.
2. Caretel Infotech Ltd. v. Hindustan Petroleum Corporation Ltd. (2019) 14 SCC 81.
3. State of Jharkhand v. Linde India Ltd. (2022) 107 GSTR 381.

Important Statutes Referred

1. Constitution of India – Article 226.
2. All India Services (Performance Appraisal Report) Rules, 2007.