Disciplinary and appellate orders lacking specific reasoning are non-speaking and legally unsustainable quasi-judicial acts.

The petitioner, a Junior Engineer, was accused of causing financial loss to the respondent company by unauthorizedly using a password to extend credit benefits to consumers

Following a departmental inquiry, the disciplinary authority imposed a punishment of withholding one annual increment without cumulative effect via an order dated August 31, 2017

The petitioner’s subsequent appeal was rejected by the appellate authority on June 28, 2022

The petitioner approached the High Court under Article 226 of the Constitution, seeking to quash these orders and claiming consequential benefits

1. Whether the disciplinary and appellate authorities exercised their quasi-judicial powers properly by passing speaking and reasoned orders

2. Whether the impugned orders of punishment and rejection of appeal are legally sustainable if they fail to record justifiable reasons for their conclusions

The court primarily applied the principles of natural justice and administrative law governing quasi-judicial authorities, emphasizing that such bodies must pass "speaking orders" that reflect an application of mind

The court relied on the Supreme Court precedent in State of Punjab v. Bandip Singh, which mandates that administrative decisions must be self-sustaining and impregnated with reasons to avoid capriciousness

Furthermore, it cited Kranti Associates Pvt. Ltd. v. Masood Ahmed Khan, which establishes that recording reasons is an indispensable component of the decision-making process and the "soul of justice"

The Court examined the text of the punishment and appellate orders, noting that while they referenced the inquiry report and the petitioner's replies, they failed to discuss the specific facts or the grounds raised in the petitioner's defense

The Court observed that a quasi-judicial authority must demonstrate that relevant factors were objectively considered

In this case, the disciplinary authority merely expressed agreement with the inquiry report without providing independent justification

Similarly, the appellate authority passed a non-speaking order that did not address the merits of the appeal

The Court reasoned that without recorded reasons, the "affected party" cannot know how their defense was evaluated, rendering the process arbitrary

It quashed the punishment order dated August 31, 2017, and the appellate order dated June 28, 2022

The respondents were directed to provide all consequential benefits to the petitioner within three months, though the Court granted the respondents liberty to initiate fresh action in accordance with the law