MP HC Sets Aside Gram Rojgar Sahayak’s Duty Restriction For Now, Orders Fresh Hearing Over CEO’s Unreasoned Order

In brief

The question

Whether the CEO’s order restraining the petitioner from performing her duties was invalid for failing to give reasons addressing her explanation.

The court held

The Court set aside the order dated 30 September 2026.

It also directed

It directed the petitioner to submit a detailed reply to the show-cause notice, together with the earlier inquiry report, within ten days.

The CEO must then provide a personal hearing to the petitioner and complainant and pass a detailed, reasoned order within two months of receiving a certified copy of the judgment, taking the earlier inquiry report into account.

The petition was disposed of without any opinion on the merits.

01Facts

The petitioner, a Gram Rojgar Sahayak, challenged the CEO, Zila Panchayat, Morena’s order dated 30 September 2026 restraining her from performing her duties and reducing her honorarium to 50%.

¶ 2–3, 10

The order followed a show-cause notice issued after complaints against her.

¶ 3–7

The petitioner relied on an earlier inquiry report that had found no evidence against her and contended that the CEO had rejected her explanation without reasons.

¶ 3–7

The State defended the order as reasoned and argued that the petitioner should appeal to the Collector.

¶ 8

02Issues

i.Whether the CEO’s order restraining the petitioner from performing her duties was invalid for failing to give reasons addressing her explanation.

¶ 10–17

ii.Whether the petitioner should be required to pursue the alternative remedy of appeal before the Collector despite the alleged absence of reasons in the impugned order.

¶ 17

03Law Applied

Under Article 226 of the Constitution, a quasi-judicial authority exercising power that affects a person’s rights must pass a reasoned, speaking order demonstrating application of mind to the relevant facts and submissions.

¶ 11–13

State of Punjab v. Bandip Singh, (2016) 1 SCC 724, requires administrative decisions to be informed by reasons and not be arbitrary or capricious.

¶ 14–15

Kranti Associates Pvt. Ltd. v. Masood Ahmed Khan, (2010) 9 SCC 496, recognises that reasons are essential to fair decision-making, transparency, and effective judicial review.

¶ 16

As explained in Oryx Fisheries Pvt. Ltd. v. Union of India, (2010) 13 SCC 427, reasons supplied at the appellate stage cannot cure the absence of reasons in the original order.

¶ 17

The applicable Gram Rojgar Sahayak policy dated 24 June 2025 was also invoked: clause 6.2 concerns a preliminary inquiry, while paragraph 6(4) provides for restraint from duties and payment of 50% honorarium.

¶ 2, 6, 10

04Reasoning

The impugned order stated that the petitioner’s reply was unsupported by “solid evidence” and unsatisfactory, and concluded that she was prima facie guilty, but did not explain why her submissions or the earlier inquiry report were rejected.

¶ 10–12, 17

Because the order affected her work and honorarium, the CEO was required to disclose the reasons for that conclusion.

¶ 10–12, 17

The absence of reasons also prevented the petitioner from effectively challenging the decision on appeal; the State’s alternative-remedy objection therefore failed.

¶ 17

The Court did not determine the merits of the allegations.

¶ 20