Gujarat High Court

### Acquittal in Criminal Trial Based on Identical Facts Warrants Review of Dismissal Order

Dalabhai Radhnathbhai Manvar v. State of Gujarat & Ors. [R/Special Civil Application No. 17296 of 2023]

Gujarat High CourtJUDGMENT: no citation2 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner, a Guardsman in the Border Wing of the Home Guard, was disembodied (terminated) from service vide order dated 23.03.2000

Source reference: p. 2

This action followed criminal proceedings under the Prevention of Corruption Act, 1988 (Special Case No. 7 of 2001).

Source reference: no citation

On 06.10.2006, the Fast Track Court, Palanpur, acquitted the petitioner

Source reference: p. 3

His subsequent representation for reinstatement was rejected on 14.11.2006.

Source reference: no citation

The State’s appeal against the acquittal (Criminal Appeal No. 145 of 2007) was eventually dismissed by the High Court on 12.07.2023, confirming the acquittal

Source reference: p. 4

The petitioner approached the High Court seeking a review of his termination and reinstatement given his final acquittal and the fact that he has approximately three months of service remaining before superannuation

Source reference: p. 5
02

Issues

Whether the respondent authorities are required to review/reconsider the petitioner's order of termination in light of his subsequent honorable acquittal in the relevant criminal trial.

Source reference: p. 5, para 8
03

Law Applied

The court primarily relied on the principles established in *G.M. Tank v. State of Gujarat and Ors.* (2006) 5 SCC 446, which holds that if an employee is honorably acquitted in a criminal trial involving the same facts and evidence as the departmental proceedings, a dismissal based on those findings is unsustainable

Source reference: p. 4

Furthermore, the court applied Government Resolution (GR) dated 19.04.2004, specifically Clause III, which mandates that decisions taken in departmental inquiries can be reviewed once a judgment in a corresponding criminal trial becomes available

Source reference: p. 5-6
04

Reasoning

The court observed that the petitioner’s termination in 2000 was not preceded by a formal departmental inquiry

Source reference: p. 6, para 8

Since the acquittal has now been confirmed by the High Court in 12.07.2023, the court found legal merit in the petitioner’s request for a review of the termination order.

Source reference: no citation

The court rejected the State's argument that the proximity of the petitioner's superannuation (May 2026) rendered the petition moot, noting that the petitioner had been diligent in filing the SCA within three months of the dismissal of the State’s criminal appeal

Source reference: p. 5-6

Applying the GR dated 19.04.2004, the court reasoned that the final outcome of service-related actions must be reconsidered if the underlying criminal charges result in an acquittal

Source reference: p. 6
05

Holding

The High Court allowed the petition in part, directing the State Government to reconsider and review the petitioner’s case in light of his acquittal

The court ordered the authorities to reach a decision by 30.04.2026 and communicate the same to the petitioner via Registered Post AD

Source reference: p. 6, para 9

The Rule was made absolute to this extent, with no order as to costs

Source reference: p. 7
Gujarat High Court

Original Court PDF

Dalabhai Radhnathbhai Manvar v. State of Gujarat & Ors. [R/Special Civil Application No. 17296 of 2023]

Gujarat High Court · no citation

Click to open original judgment

Original judgment, available to read, download and summarize on LawLens.in

Click to open original judgment