Disciplinary proceedings are void without the competent authority's specific approval of the draft charge-sheet.

The Petitioners (Union of India) challenged the judgment of the Central Administrative Tribunal (CAT) dated April 3, 2017, which allowed the Respondent’s application (OA 2907/2013)

The Respondent, a Deputy Commissioner in the Department of Agriculture, was subjected to disciplinary proceedings under Rule 14 of the CCS (CCA) Rules, 1965

The CAT quashed the proceedings on the ground that while the Agriculture Minister (the competent disciplinary authority) approved the initiation of the proceedings, he had not approved the actual draft charge-sheet

The Petitioners argued that the Minister’s approval of the file note, which mentioned that the articles of charge were "placed below," constituted valid approval

1. Whether the disciplinary proceedings were void ab initio due to the failure of the competent disciplinary authority to approve the draft charge-sheet prior to its issuance

2. Whether the mere enumeration of acts of misconduct in a file note satisfies the legal requirement for the approval of a formal charge-sheet

Rule 14 of the Central Civil Services (Classification, Control & Appeal) Rules, 1965

Union of India v. B.V. Gopinath (2014), which held that the initiation of disciplinary proceedings and the approval of a charge-sheet are two distinct stages, both requiring the independent application of mind and approval by the Disciplinary Authority

State of Jharkhand v. Rukma Kesh Mishra (2025), which clarifies that approval of a proposal to initiate proceedings includes the charge-sheet only if the draft charge-sheet was physically part of the record before the authority at the time of approval

Although the file note (Para 11) stated that the articles of charge were "placed below for perusal," the Court’s physical inspection revealed that the draft charge-sheet was not actually attached to the note when the Agriculture Minister signed it on January 12, 2009

The record showed the charge memorandum was only prepared on January 13, 2009—after the Minister's signature

The Court dismissed the Petitioner’s argument that the summary of misconduct in Para 10 of the note sufficed, reasoning that a charge-sheet is a formal legal document requiring specific articles of charge, imputations, and lists of witnesses/documents

Without the physical presence of the draft charge-sheet before the Minister, there was no "approval" in the eyes of the law

The Court affirmed the Tribunal's findings, holding that mere approval to initiate proceedings does not equate to approval of the charge-sheet

The writ petition was dismissed, and the Tribunal’s order quashing the disciplinary proceedings was upheld