Quasi-judicial appellate orders affecting service rights must be reasoned, speaking, and based on relevant considerations.

The petitioner, Constable No. 326, was undergoing police training during 2015–2016.

He was granted a seven-day break from 6 April 2016 to 13 April 2016 but returned on 14 April 2016, allegedly due to ill health.

Referring to Rule 24 of the Madhya Pradesh Civil Services (Leave) Rules, 1977, the authorities treated the period as unauthorised absence and withheld one increment by making an entry in his service book.

The petitioner’s appeal to the Deputy Inspector General, Chambal Range, was rejected by order dated 4 August 2025.

The appellate order stated that no ground had been shown warranting interference with the punishment, but did not provide detailed reasons dealing with the petitioner’s contentions.

The petitioner challenged the order under Article 226 of the Constitution, principally contending that it was unreasoned and non-speaking.

Whether the appellate order dated 4 August 2025, rejecting the petitioner’s challenge to withholding of one increment, was liable to be set aside for being non-speaking and unreasoned.

Whether the High Court should itself determine the merits of the petitioner’s claim regarding the alleged unauthorised absence and withholding of increment, or remit the matter to the appellate authority for fresh consideration.

The Court applied the principle that an appellate or administrative authority exercising quasi-judicial power must pass a reasoned and speaking order after considering the relevant facts and contentions.

Relying on State of Punjab v. Bandeep Singh, (2016) 1 SCC 724, the Court held that an administrative or executive decision must be composite, self-sustaining, and contain the reasons that prevailed with the decision-maker.

It also relied on Kranti Associates (P) Ltd. v. Masood Ahmed Khan, (2010) 9 SCC 496, which establishes that quasi-judicial authorities must record cogent reasons; reasons ensure fairness, restrain arbitrariness, facilitate judicial review, and demonstrate consideration of relevant factors.

The Court further applied the requirement that discretion must be exercised diligently, reasonably, and rationally.

The appellate authority merely recorded that the petitioner had failed to present facts justifying interference with the punishment.

It did not meaningfully examine the petitioner’s explanation for returning on 14 April 2016, the application allegedly submitted by him, the application of Rule 24, or the basis for withholding the increment.

Since the appeal concerned a service-related penalty affecting the petitioner’s financial and employment rights, the appellate authority was required to independently apply its mind and give reasons.

The absence of a reasoned consideration rendered the order non-speaking and legally unsustainable.

However, because the defect related to the decision-making process rather than the substantive merits of the absence or punishment, the High Court considered it appropriate to remit the matter instead of deciding the merits itself.

The petitioner was directed to file a fresh appeal before the appellate authority within one month, and the appellate authority was directed to decide it by passing a speaking and reasoned order after granting the petitioner a personal hearing, within two months from receipt of the certified copy of the judgment.

The Court expressly clarified that it had not expressed any opinion on the merits of the petitioner’s claim.