Administrative orders lacking reasoned findings on proportionality of punishment are unsustainable and warrant remand for reconsideration.

Respondent 1, Prof. Rajesh Anand, was served a charge sheet dated 24 April 2014, which led to disciplinary proceedings and his eventual dismissal from service on 15 June 2016

Respondent 1 challenged this dismissal before the Central Administrative Tribunal (CAT) in OA 2519/2016

In its judgment dated 28 February 2022, the Tribunal set aside the dismissal and ordered reinstatement with notional benefits, holding that the punishment was disproportionate to the proven delinquency

The Petitioners (UGC) challenged this order before the Delhi High Court, arguing that the Tribunal failed to provide reasons for its finding on proportionality

1. Whether the Central Administrative Tribunal’s order was legally sustainable given the lack of specific reasoning regarding the proportionality of the punishment

2. Whether the matter should be remanded to the Tribunal for a reasoned reconsideration of the proportionality of the dismissal

The court applied the fundamental principle of administrative and judicial review that any order setting aside a disciplinary punishment on the grounds of "proportionality" or "shocks the judicial conscience" must be supported by cogent reasons

It further followed the principle of remand, where a superior court sends a matter back to the lower forum when the impugned order is found to be unreasoned or "peculiar" in its silence on the merits of the case

The High Court observed that the Tribunal’s judgment was intellectually "peculiar" because the first ten paragraphs merely recited facts, and the actual decision to set aside the dismissal (paragraphs 12 and 13) contained no analysis of the merits, the Inquiry Officer’s findings, or why exactly the charges were not "grave" enough for dismissal

The court noted that while the Tribunal has the power to interfere if a punishment "shocks the judicial conscience," it must provide a "real reason" for such a conclusion

Since the Respondent did not challenge the Tribunal’s order, the actual findings of the disciplinary proceedings were no longer open to challenge; the only surviving scrutiny was the quantum of punishment

The court found that the lack of reasoning rendered the order unsustainable, necessitating a remand for the limited purpose of justifying the proportionality of the penalty

The Court held that the order lacked sufficient reasons for finding the punishment disproportionate

The matter was remanded to the Central Administrative Tribunal (OA 2519/2016) for the limited purpose of reconsidering whether the dismissal of Respondent 1 was disproportionate to the proved charges, with a specific direction to provide detailed reasons for its decision

The parties were directed to appear before the Tribunal on 22 May 2026 for an expedited hearing