Authorities Must Give Reasoned Orders When Rejecting Appeals Against Adverse ACRs.

The petitioner, an Assistant Manager posted at Keeratpura Distribution Centre, Gohad, District Bhind, was assessed for 2021–22. His ACR was initially downgraded from A+ to C, with a score of 5.96, and was ultimately recorded as B by the accepting officer.

He submitted statutory appeals/representations dated 24 January 2023 and 13 February 2024. Respondent No. 2 rejected them by order dated 6 November 2024. The petitioner challenged that order under Article 226, contending that it did not address the grounds raised in his appeals.

1. Whether the order rejecting the petitioner’s ACR appeals/representations was invalid for being non-speaking and unreasoned.

2. Whether the petitioner was entitled to a direction that the ACR be upgraded to Outstanding Grade (A+) and consequential service benefits.

Under Article 226, a decision by an authority exercising quasi-judicial power that affects a person’s rights must be supported by reasons; the order itself must disclose the basis for the decision. Reasons constrain arbitrary discretion and facilitate judicial review.

The Court relied on State of Punjab v. Bandip Singh, (2016) 1 SCC 724, for the principle that an administrative or executive decision must be self-sustaining and contain the reasons informing the conclusion, and on Kranti Associates Pvt. Ltd. v. Masood Ahmed Khan, (2010) 9 SCC 496, for the requirement that quasi-judicial authorities record cogent reasons and that affected parties be able to understand how their case was considered.

The impugned order rejected the petitioner’s appeals after referring generally to consideration of his representation, revenue figures and service record, but did not address the facts and grounds raised by him or explain why the ACR grading was maintained.

Applying the requirement of reasoned decision-making to this order, the Court held that it was non-speaking and therefore could not stand. The Court expressly left the merits of the ACR grading undecided.

It directed the petitioner to submit a fresh representation to Respondent No. 2 within 15 days and directed the competent authority/review committee to provide him a personal hearing and pass a reasoned, speaking order within six weeks of receiving the certified copy of the judgment. The Court expressed no opinion on the merits, and disposed of the petition.