Examining authority must decide post-acquittal representations against disqualification through a reasoned, speaking order.

The petitioner participated in the M.P. State Civil Services Examination, 2012 conducted by the Madhya Pradesh Public Service Commission (“MPPSC”), cleared the Preliminary and Main Examinations, and secured Merit Position No. 508, making him eligible for the interview.

Following registration of Crime No. 14/2014 by the STF, Bhopal, MPPSC issued him a show-cause notice on 20 May 2016. After considering his reply, MPPSC disqualified him from the examination for the period from 1 October 2013 to 1 October 2015 by order dated 8 July 2016, relying on Rule 16 of the State Service Examination Rules, 2008.

The petitioner challenged the order before the High Court and, pursuant to an interim order dated 11 July 2016, appeared in the interview; however, his result was withheld.

His writ petition and writ appeal were subsequently dismissed, with liberty to approach the competent authority.

The criminal case ultimately ended in his acquittal by judgment dated 9 April 2026. Thereafter, he submitted a representation seeking removal of the disqualification, but the representation was not decided, leading to the present petition.

1. Whether respondent No. 2 was required to consider and decide the petitioner’s representation seeking removal of his examination-related disqualification following his acquittal in the criminal case.

2. Whether respondent No. 2 was required to pass a reasoned and speaking order after examining the effect of the acquittal, the status of any appeal, and the treatment accorded to similarly situated candidates.

The Court considered Rule 16 of the State Service Examination Rules, 2008, under which the petitioner had originally been disqualified on account of the criminal case.

It applied the administrative-law principle that a competent authority must objectively consider a representation and issue a reasoned and speaking order, particularly where the representation relies on a subsequent material development, namely, acquittal in the criminal case.

The Court also directed the authority to consider relevant and comparable cases, including the appointment or promotion of a similarly situated person, while determining the petitioner’s claim.

No final legal rule was laid down that acquittal automatically nullifies the earlier disqualification; instead, the effect of the acquittal was left for determination by the competent authority in accordance with law.

The petitioner’s disqualification had been imposed in connection with the criminal case, and he subsequently obtained an acquittal on all charges.

This subsequent development rendered his representation deserving of consideration by MPPSC.

Although respondent No. 2 contended that the petition was premature because it had only recently received the representation, the Court accepted that the proper course was to require the authority to examine the acquittal judgment, verify whether any appeal had been filed, and determine whether the acquittal affected the petitioner’s disqualification.

The Court therefore declined to directly order removal of the disqualification and instead required MPPSC to exercise its decision-making power through a reasoned and speaking order.

It further required consideration of the fact that a similarly situated person, Bhanu Pratap Singh, had been appointed or promoted as Naib Tehsildar after acquittal in the relevant criminal case.

MPPSC was directed to consider the acquittal judgment, verify whether it had been challenged, determine its effect on the petitioner’s disqualification, and take into account the treatment of similarly situated persons, including Bhanu Pratap Singh.

The Court did not itself direct appointment, declaration of eligibility, or automatic removal of the disqualification.