Quasi-judicial authorities must pass reasoned speaking orders to satisfy the principles of natural justice.

The Petitioner, a retired Grade C Secretary of the Krishi Upaj Mandi Samiti, challenged a punishment order dated 13.07.2017

In 2016, the Petitioner was charge-sheeted for the issuance of 20 forged gate passes during his 2013 posting at Bhind

Although the Enquiry Officer’s report did not find the Petitioner directly responsible for the forgeries, it concluded he was liable for delays in following headquarters' directions

Consequently, the disciplinary authority imposed a penalty of 10% pension deduction for three years and forfeited all benefits during his suspension period except for the subsistence allowance

The Petitioner contended that the disciplinary authority failed to consider his detailed reply dated 01.05.2017 and passed a non-speaking, unreasoned order

1. Whether the impugned punishment order dated 13.07.2017 passed by the disciplinary authority was a speaking and reasoned order

2. Whether the failure of a quasi-judicial authority to record reasons for a decision affecting the rights of a party vitiates the legality of that decision

The court primarily relied on the principle that quasi-judicial and administrative authorities must pass reasoned, "speaking orders" to prevent the arbitrary exercise of power

It applied the precedent from State of Punjab v. Bandip Singh (2016) 1 SCC 724, which mandates that executive decisions must be self-sustaining and contain all prevailing reasons

the court invoked Kranti Associates Pvt. Ltd. v. Masood Ahmed Khan (2010) 9 SCC 496 and Oryx Fisheries Pvt. Ltd. v. Union of India (2010) 13 SCC 427, establishing that recording reasons is an indispensable component of natural justice and the "soul of justice," facilitating judicial review and ensuring transparency

The authority to impose punishment was derived from Regulation 30(7) of the M.P. Rajya Mandi Board Service Regulations, 1998

The Court observed that the disciplinary authority, while imposing punishment, exercised quasi-judicial power and was thus legally obligated to apply its mind to the specific grounds raised in the Petitioner’s reply

Upon perusing the punishment order, the Court found it to be non-speaking and unreasoned, noting that while the order mentioned the existence of the Petitioner’s reply, it failed to actually consider or address the facts and grounds contained therein

The Court emphasized that an order affecting a party's rights must not be "inscrutable" and must demonstrate an objective consideration of relevant factors to sustain the litigant's faith in the justice system

Since the disciplinary authority failed to provide a rational nexus between the material on record and the conclusion reached, the order was held to be capricious and arbitrary

The Court directed the respondents to grant all consequential benefits to the Petitioner within three months

Given that the Petitioner had already retired and was 69 years of age, the Court explicitly declined to grant the respondents liberty to initiate fresh action against him