Disciplinary and appellate orders lacking reasons are non-speaking and liable to be quashed.

The petitioner, a Deputy General Manager (Current Charge) at the S.T.C. Division, Morena, was issued a show-cause notice on 09.08.2024 alleging misconduct.

Despite submitting a detailed reply on 29.10.2024, the Disciplinary Authority passed an order on 17.12.2024 imposing a penalty of recovery equivalent to one annual graded increment.

The petitioner retired on 28.02.2025 and subsequently challenged the penalty before the Appellate Authority, which rejected the appeal on 11.09.2025.

The petitioner approached the High Court under Article 226 of the Constitution, contending that both orders were non-speaking and unreasoned.

1. Whether the Disciplinary and Appellate Authorities, while exercising quasi-judicial powers, are legally obligated to pass speaking and reasoned orders.

2. Whether the impugned orders dated 17.12.2024 and 11.09.2025 are sustainable in the absence of valid and justifiable reasons supporting their conclusions.

The fundamental principle of administrative law that quasi-judicial authorities must pass speaking orders.

State of Punjab v. Bandip Singh, (2016) 1 SCC 724: Administrative decisions must be self-sustaining and impregnated with reasons.

Kranti Associates Pvt. Ltd. v. Masood Ahmed Khan, (2010) 9 SCC 496: Recording reasons is an indispensable component of the decision-making process, a part of natural justice, and a requirement for sustaining faith in the justice delivery system.

The Court examined the text of the Disciplinary Authority’s order and observed that while it acknowledged the petitioner’s reply, it failed to record any specific reasons as to why the reply was "unsatisfactory".

The Court noted that as a quasi-judicial body, the authority must demonstrate an application of mind to the facts and circumstances.

Regarding the Appellate Authority, the Court found that the order merely stated that no new facts were presented to justify interference, without addressing the grounds raised in the appeal.

Citing Kranti Associates, the Court emphasized that reasons are the "lifeblood of judicial decision-making" and that an order must not be like the "inscrutable face of a sphinx"; since both authorities failed to provide the "why" behind their conclusions, the orders were found to be arbitrary and violative of the principles of natural justice.

The Court quashed the punishment order dated 17.12.2024 and the appellate order dated 11.09.2025, directing respondents to provide all consequential benefits within three months, while granting liberty to initiate fresh action if necessary.