Disciplinary orders must be reasoned and reflect active consideration of the delinquent's response.

The petitioner, an unskilled laborer, was subjected to a departmental proceeding following a memo of charges dated February 7, 2013, alleging he used abusive language and threatened an Assistant Engineer

The Conducting Officer found the charges proved, and the petitioner was served with a second show-cause notice along with the inquiry report

On June 24, 2014, the Disciplinary Authority (Respondent No. 5) inflicted a punishment consisting of the stoppage of one annual increment (non-cumulative) and the forfeiture of salary during the suspension period beyond the subsistence allowance already paid

The petitioner’s appeal was rejected by the Chairman-cum-Managing Director on January 29, 2021

The petitioner challenged these orders on the grounds that his detailed reply to the second show-cause notice was not considered, violating principles of natural justice and statutory rules

1. Whether the order of punishment passed by the Disciplinary Authority was legally sustainable given the alleged lack of consideration of the petitioner’s reply and absence of reasoned findings?

2. Whether the appellate order confirming the punishment was valid in law?

Rule 19(1)(d) of the Bihar Government Servants (Classification, Control & Appeal) Rules, 2005 (CCA Rules), which mandates consideration of the delinquent's representation

Kranti Associates Private Limited and Another v. Masood Ahmed Khan and Others (2010) 9 SCC 496, which dictates that quasi-judicial and administrative authorities must record clear, cogent, and succinct reasons to ensure transparency and prevent arbitrariness

The Court observed that while the petitioner submitted a detailed reply to the second show-cause notice raising substantial points, the Disciplinary Authority’s order dated June 24, 2014, merely stated that the reply and evidence were "considered" without actually discussing the contentions raised

Applying the Kranti Associates precedent, the Court held that a "pretence of reasons" or "rubber-stamp reasons" do not constitute a valid decision-making process

The Court found that the failure to address the petitioner’s specific defenses rendered the order devoid of any objective consideration

Furthermore, the Court noted that the summary rejection of the appeal by Respondent No. 2 suffered from the same lack of independent reasoning

The Court allowed the writ petition and quashed the punishment order dated June 24, 2014, and the appellate order dated January 29, 2021

The matter was remanded to the respondent authorities to proceed from the stage of the petitioner’s reply to the second show-cause notice, with a direction to conclude the proceeding with a reasoned order within four months