Madhya Pradesh High Court

Administrative orders rejecting representations against adverse ACRs must be speaking and reasoned, not cursory.

Sukhdev Singh Yadav vs The State Of Madhya Pradesh

Madhya Pradesh High CourtJUDGMENT: July 21, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner, Sukhdev Singh Yadav, challenged an order dated 28-10-2025 [Annexure P/1] passed by the competent authority, which rejected his representation against an adverse Annual Confidential Report (ACR) for the year 2024.

Source reference: p. 1

The adverse ACR graded the petitioner as "Category D," citing indiscipline, absence from duty, and misbehavior with senior officers.

Source reference: para. 6

The petitioner contended that the impugned order was non-speaking and unreasoned, as it failed to consider the specific grounds and facts raised in his representation.

Source reference: para. 2, 5
02

Issues

1. Whether the administrative order rejecting the petitioner's representation against the adverse ACR was a speaking and reasoned order in accordance with the principles of natural justice.

Source reference: para. 5, 7

2. Whether an administrative or quasi-judicial authority is mandated to record specific reasons when passing an order that prejudicially affects the rights of a party.

Source reference: para. 8, 11
03

Law Applied

The court applied the fundamental principle of administrative law requiring the exercise of discretionary power in a reasonable and rational manner.

Source reference: para. 8

It relied on State of Punjab v. Bandip Singh, which held that executive decisions must be self-sustaining and contain all prevailing reasons.

Source reference: para. 9, 10

The court further applied the principles from Kranti Associates Private Limited v. Masood Ahmed Khan, which established that recording reasons is an indispensable component of the decision-making process, ensuring transparency, accountability, and facilitating judicial review.

Source reference: para. 11
04

Reasoning

Upon perusal of the impugned order, the court found that the competent authority merely reiterated the adverse remarks of the reporting officer and dismissed the representation by stating that no "solid arguments" were presented.

Source reference: para. 6, 7

The court observed that the authority failed to deal with the specific grounds raised by the petitioner, resulting in an order that was "cursory" and "like the inscrutable face of a sphinx".

Source reference: para. 7, 11

By failing to provide cogent and succinct reasons, the authority violated the "lifeblood of judicial decision-making".

Source reference: para. 11(h)

The court reasoned that since the order lacked transparency and did not demonstrate an objective consideration of relevant factors, it could not be sustained in its current form.

Source reference: para. 11(i), 12
05

Holding

The court held that the impugned order was non-speaking and lacked adequate reasoning.

Without expressing an opinion on the merits, the court disposed of the petition with a direction to the petitioner to submit a fresh, detailed representation to respondent No. 2 (DIG) within two weeks; Respondent No. 2 was directed to consider both the fresh and earlier representations and pass a speaking and reasoned order in accordance with the law within two months.

Source reference: para. 12, 13, 14
Madhya Pradesh High Court

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Sukhdev Singh YadavvsThe State Of Madhya Pradesh

Madhya Pradesh High Court · July 21, 2026

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