Quasi-judicial authorities cannot make irrelevant personal aspersions against litigants; such remarks must be expunged.

The petitioner complained that a Government-constructed drain in his village had become clogged, causing seepage and alleged obstruction to cultivation on his agricultural land.

The Block Development Officer initially reported defects in the drain but later stated that, with the petitioner’s consent, drainage water had earlier been allowed to flow into his land and that the petitioner subsequently stopped the flow.

The Sub-Divisional Public Grievance Redressal Officer directed repair of the drain and concluded the proceeding on 20 September 2022.

The petitioner’s first appeal was dismissed on the ground that a land-related dispute had rendered the drain non-functional.

In the second appeal, the District Magistrate-cum-Second Appellate Authority dismissed the petitioner’s case on 25 February 2023 and made remarks that the petitioner appeared to have a mentality to harass members of the Scheduled Caste/Scheduled Tribe communities residing nearby.

The petitioner sought review before the Divisional Commissioner, but the review was rejected on 2 May 2023 on the ground that the Bihar Public Grievance Redressal Act, 2015 contained no power of review.

During the writ proceedings, a subsequent joint inspection report stated that the drain was dry, no continuous source of water-flow onto the petitioner’s land was found, and no waterlogging was visible.

Whether the High Court should interfere with the administrative orders concerning the alleged drain blockage and waterlogging on the petitioner’s land?

Whether the personal and stigmatic remarks made by the District Magistrate against the petitioner were legally impermissible and liable to be expunged?

Whether the statutory protection under Section 10 of the Bihar Public Grievance Redressal Act, 2015 barred challenge to the remarks, and whether the reviewing authority correctly declined review under Section 9?

The Court applied the principle that quasi-judicial authorities must determine disputes strictly on the basis of relevant facts and law and must use sober, temperate and respectful language; personal attacks, irrelevant observations and remarks concerning a litigant’s character, morality or background, when unrelated to the adjudication, constitute an abuse of power.

Relying on A.M. Mathur v. Pramod Kumar Gupta, (1990) 2 SCC 533, the Court reiterated that judicial restraint and discipline are essential to the proper administration of justice and that adjudicatory authorities must focus on the merits rather than make personal comments.

The Court also considered the State’s reliance on Sections 9 and 10 of the Bihar Public Grievance Redressal Act, 2015, concerning the limits of review and protection for acts done in good faith under the Act.

The Court declined to interfere with the substantive administrative findings regarding the drain because the subsequent physical verification found no visible waterlogging and no continuous source of water flowing onto the petitioner’s land.

However, the District Magistrate’s observation that the petitioner had a mentality to harass SC/ST residents was unrelated to the determination of whether the drain was blocked or whether waterlogging existed.

Such a stigmatic conclusion was not shown to be supported by relevant material and violated the requirement that quasi-judicial authorities act objectively and confine themselves to the dispute before them.

The statutory protection under Section 10 could not justify irrelevant or unwarranted personal aspersions, while the question of review did not validate the remarks themselves.

Accordingly, the Court preserved the substantive administrative orders but removed the offending observations.

However, the Court held that the District Magistrate’s uncharitable and unwarranted personal remarks against the petitioner were impermissible and directed that the order dated 25 February 2023 be expunged to the extent that it contained personal aspersions against the petitioner.