Judicial review of suspension is restricted to procedural impropriety, mala fides, or total absence of evidence.

The applicant, an Indian Forest Service (IFS) officer of the 2012 batch, was serving as the Deputy Conservator of Forests (DCF), M.M. Hills Wildlife Division

On 26.06.2025, a tigress and four cubs were found dead due to poisoning via a contaminated cow carcass

A High-Level Inquiry Committee reported that salaries for outsourced anti-poaching watchers had not been paid for March, April, and May 2025, leading to staff protests on 23.06.2025, just three days prior to the incident

The inquiry attributed the lapse to administrative failure and negligence by the applicant, noting that funds were available by late April 2025 but bills were not processed timely

Consequently, the State Government of Karnataka suspended the applicant on 14.07.2025 pending inquiry

The applicant challenged the suspension, alleging a lack of material evidence and claiming he only received the formal budget approval on 02.07.2025, after the incident

1. Whether the suspension order dated 14.07.2025 was arbitrary, illegal, or lacked sufficient prima facie evidence to warrant the applicant's removal from duty pending inquiry

2. Whether the scope of judicial review permits the Tribunal to interfere with a suspension order where administrative failure and negligence are alleged in a matter of extreme gravity

The court applied Rule 3(1)(a) of the All India Service (Discipline & Appeal) Rules, 1969, which empowers the government to suspend an officer pending inquiry

It relied on Jayrajbhai Jayantibhai Patel v. Anilbhai Nathubhai Patel (2006), establishing that judicial review is limited to procedural impropriety or illogicality rather than the decision's merits

Furthermore, it cited State of Orissa v. Bimal Kumar Mohanty (1994) and Union of India v. Ashok Kumar Aggarwal (2013), which hold that suspension is not a punishment but an interim measure to ensure unhindered proceedings, and courts should not interfere unless the order is mala fide or lacks any prima facie evidence

The Tribunal observed that the death of five tigers was an incident of "extreme gravity" and national importance

While the applicant argued that the delay in wage payments was due to the late receipt of the Annual Plan of Operation (APO) on 02.07.2025, the Tribunal scrutinized the office Inward/Receipt Registers.

It found "strong suspicion" regarding the applicant's knowledge of the budget sanction, noting discrepancies where the applicant's office marked receipt on 02.07.2025 while the register showed 08.07.2025, suggesting a potential attempt to shield the office from negligence

The Tribunal emphasized that even if the contractor was contractually bound to pay wages initially, the applicant, as Head of Office, failed in his basic duty to ensure timely disbursement despite fund availability in April

Following the principles in Ashok Kumar Aggarwal, the Tribunal held it cannot act as an appellate forum for factual disputes at the suspension stage; the presence of the Inquiry Committee’s findings of administrative failure provided sufficient "mischief range" to justify keeping the officer out of duty to prevent interference with the investigation

It held that there was sufficient material evidence on record to justify the suspension based on prima facie negligence and dereliction of duty

The Tribunal noted that the suspension had been duly confirmed by the Central Government within the mandatory 30-day period, and no grounds for judicial interference existed

The parties were ordered to bear their own costs