Appellate disciplinary authorities must address every ground through a reasoned, speaking order.

The petitioner, a police constable, was subjected to the punishment of withholding one annual increment with cumulative effect by the Superintendent of Police, Morena, through order dated 20 November 2024.

The petitioner preferred an appeal before the Deputy Inspector General, Chambal Range, Morena, raising various grounds. The appeal was rejected by order dated 5 March 2025, which, according to the petitioner, did not consider the grounds raised or provide adequate reasons.

The petitioner thereafter filed a mercy petition, which was rejected by order dated 9 April 2026; the order was received by him on 27 June 2026.

In the writ petition under Article 226 of the Constitution, the petitioner sought quashing of the disciplinary, appellate and mercy-petition orders, restoration of the withheld increment, and consequential arrears with interest.

1. Whether the appellate order dated 5 March 2025 was liable to be quashed for being non-speaking and for failing to consider the grounds raised in the petitioner’s appeal?

2. Whether the order dated 9 April 2026 rejecting the mercy petition could stand when the underlying appellate decision lacked adequate reasons?

3. Whether the petitioner was entitled to a fresh consideration of his appeal by the competent appellate authority after an opportunity of personal hearing?

The Court applied Article 226 of the Constitution and the settled principle that disciplinary and appellate authorities exercising quasi-judicial power must pass reasoned, speaking and self-contained orders after applying their minds to the relevant facts and grounds.

Relying on State of Punjab v. Bandip Singh, (2016) 1 SCC 724, the Court held that every administrative or executive decision affecting rights must contain the reasons that prevailed with the decision-maker and cannot be arbitrary or capricious.

The Court also relied on Kranti Associates (P) Ltd. v. Masood Ahmed Khan, (2010) 9 SCC 496, which establishes that recording reasons is an essential component of fair administrative and quasi-judicial decision-making, restrains arbitrary exercise of power, facilitates judicial review, and requires reasons to be cogent, clear and succinct.

The appellate order merely recorded the disciplinary authority’s allegation that the petitioner had failed to issue or maintain records concerning summons and warrants and concluded that the petitioner had not furnished any material reducing the seriousness of the charge.

It did not demonstrate meaningful consideration of the specific grounds raised in the appeal.

Since the disciplinary authority and appellate authority were exercising quasi-judicial powers affecting the petitioner’s service rights, they were required to record reasons showing application of mind to the petitioner’s defence and the grounds of appeal.

The appellate order therefore failed the requirement of a speaking and reasoned decision.

The subsequent rejection of the mercy petition could not cure this defect; consequently, both the appellate order and the mercy-petition order were set aside.

The Court clarified that it had not expressed any opinion on the merits of the disciplinary charge.

The petitioner was directed to submit a fresh and comprehensive appeal before the DIG, Chambal Range, Morena, within one month.

The appellate authority was directed to decide the appeal afresh, by a reasoned and speaking order, within three months of receiving it; it must consider the grounds raised in both the earlier and fresh appeals and afford the petitioner a personal hearing.

The Court did not decide the merits of the disciplinary action, and the writ petition was disposed of accordingly.