Departmental punishment is unsustainable when criminal acquittal rests on substantially identical charges and evidence.

The petitioner, a Civil Police Constable, was charged departmentally over alleged wrongful confinement and assault of a complainant on 20 June 2015.

The enquiry officer found the charges proved, and the disciplinary authority imposed the penalty of withholding two annual increments with cumulative effect; the appeal was dismissed.

The petitioner challenged those orders before the Karnataka State Administrative Tribunal, which rejected his applications.

In the related criminal case, the petitioner was acquitted after the trial court found that the prosecution had failed to prove his guilt.

He then sought judicial review of the Tribunal’s decision.

An acquittal in a criminal case does not automatically invalidate a disciplinary penalty.

However, where the charges, evidence, witnesses, and circumstances in the criminal and departmental proceedings are identical or substantially similar, sustaining the disciplinary findings may be unjust, unfair, and oppressive.

The court also relied on G.M. Tank v. State of Gujarat and Ramlal v. State of Rajasthan, emphasizing that the substance and basis of the acquittal—not merely labels such as “benefit of doubt” or “honourably acquitted”—must be considered.

The Court compared the criminal and departmental records and found that the proceedings concerned substantially the same allegations and included several common witnesses, including the complainant.

The trial court’s acquittal rested on its finding that the prosecution had failed to prove the petitioner’s guilt, rather than on a merely technical ground.

Applying the principle in Maharana Pratap Singh, the Court held that, in these circumstances, the Tribunal erred in allowing the disciplinary findings and penalty to stand.

It quashed the appellate order dated 22 June 2017 and the disciplinary penalty order dated 23 March 2017.