Absence from Mandatory election duty warrants minor penalty regardless of pending exemption application.

The appellant, a teacher substantively appointed as Uchcha Madhyamik Shikshak, was assigned election duty as a Presiding Officer during the Lok Sabha Elections.

He remained absent from duty, claiming he had family obligations regarding a relative’s marriage and had verbally been assured of an exemption after submitting an application.

Consequently, a show-cause notice was issued on 12.05.2024.

Dissatisfied with his reply, the disciplinary authority imposed a minor penalty of stoppage of two increments without cumulative effect on 17.01.2025, which was upheld by the appellate authority on 21.04.2025.

The appellant challenged these orders via W.P. No. 21522/2025, which was dismissed by a Single Judge on 22.01.2026.

1. Whether the disciplinary authority was required to conduct a full-scale formal inquiry before imposing a minor penalty when the employee had submitted a detailed explanation to a show-cause notice

2. Whether the absence from mandatory statutory election duty can be justified by the mere submission of an exemption application without a formal order of approval

3. Whether the High Court, in its writ jurisdiction, can interfere with the findings of disciplinary and appellate authorities regarding the sufficiency of reasons for absence

Section 2(1) of the Madhya Pradesh Uchcha Nyayalaya (Khand Nyayapeeth Ko Appeal) Adhiniyam, 2005 regarding the maintainability of the writ appeal.

Principle from O.K. Bhardwaj v. Union of India (2001) 9 SCC 180, which discusses the necessity of an opportunity of hearing even for minor penalties.

Kranti Associates Private Limited v. Masood Ahmed Khan (2010) 9 SCC 496, establishing that quasi-judicial orders must contain adequate reasons.

The Court emphasized that judicial review is limited to the decision-making process and not the merits of the decision unless the findings are arbitrary or mala fide.

The Court reasoned that election duty is a statutory and mandatory obligation that cannot be bypassed by a mere request for exemption; a formal order of relief is required.

Distinguishing the precedents cited by the appellant (Arvind Kumar Sandilya and Jagdish Prasad Yadav), the Court found that the appellant was not "condemned unheard" because he was served a show-cause notice and his detailed reply was actually considered by the authorities.

The Court noted that the disciplinary authority’s rejection of the appellant’s personal reasons (marriage arrangements) did not constitute an arbitrary decision.

Since the procedural requirements of natural justice were met and no procedural illegality was established, the Court held that it could not sit as an appellate body over the departmental findings.

The Court affirmed that the mere submission of an application does not grant a right to remain absent from election duty.

The Writ Appeal was dismissed, and the order of the Single Judge dated 22.01.2026 was affirmed.