Quasi-judicial authorities must pass reasoned and speaking orders while deciding statutory appeals.

The petitioner was appointed as an 'Amin' in 1988

Due to his wife's mental illness and hospitalization, he remained absent from duty and applied for leave through proper channels, which the respondents allegedly ignored

Following a show-cause notice and a charge-sheet dated July 20, 2006, a departmental enquiry was conducted

Despite the petitioner's reply, the Disciplinary Authority imposed the punishment of dismissal from service

The petitioner preferred an appeal (Annexure P-10) raising nine distinct factual and legal grounds

However, the Appellate Authority rejected the appeal on October 8, 2015, via an order the petitioner contended was non-speaking and unreasoned

The petitioner subsequently challenged the dismissal and the appellate order under Article 226 of the Constitution of India

1. Whether the Appellate Authority, while exercising quasi-judicial powers, is mandated to pass a speaking order supported by valid and justifiable reasons

2. Whether the impugned appellate order dated October 8, 2015, was arbitrary and capricious for failing to address the specific grounds raised in the appeal memo

The court primarily relied on the principles of administrative law and natural justice, emphasizing that quasi-judicial authorities must pass "speaking orders"

It applied Rule 10(9) of the M.P. Civil Services (Classification, Control and Appeal) Rules, 1966, regarding the imposition of penalties

The court cited State of Punjab v. Bandip Singh (2016) 1 SCC 724, which establishes that administrative decisions must be self-sustaining and impregnated with reasons to avoid being arbitrary

Furthermore, it relied on Kranti Associates Pvt. Ltd. v. Masood Ahmed Khan (2010) 9 SCC 496, which holds that recording reasons is an indispensable component of the decision-making process and a facet of human rights and fairness

The court observed that the Appellate Authority, when reviewing the dismissal of a government servant, functions as a quasi-judicial body

Upon perusing the impugned order dated October 8, 2015, the court found it to be non-speaking

Although the State counsel argued that the authority was satisfied with the disciplinary findings, they conceded that no independent reasoning was assigned in the appellate order

The court reasoned that the "face of an order" must speak so the affected party understands how their defense was considered

By failing to address the petitioner’s specific grounds—particularly the medical exigencies regarding his wife—and merely concurring with the lower authority without analysis, the Appellate Authority acted in a mechanical and capricious manner

The court emphasized that reason is the "lifeblood of judicial decision-making" and essential for sustaining faith in the justice system

Consequently, the court set aside the appeal rejection order dated October 8, 2015 (Annexure P/2)

The petitioner was directed to submit a fresh, detailed appeal within one month from the date of the order

The Appellate Authority was further directed to decide the fresh and earlier appeals by passing a reasoned and speaking order after providing the petitioner a personal hearing, within a period of three months from the receipt of the certified copy

The petition was disposed of with these directions