### Quasi-judicial Orders Must Be Speaking Orders with Cogent Reasons Supportings Conclusions Case Brief: Facts: The petitioner, an Assistant Manager, challenged a disciplinary order (28.12.2023) withholding annual increments and a subsequent appellate order (27.10.2025) rejecting his appeal. The petitioner contended that both orders were non-speaking, unreasoned, and failed to consider the merits of his explanation and grounds for appeal. Issue: Whether a disciplinary or appellate authority, while exercising quasi-judicial powers, is legally obligated to pass a reasoned and speaking order. Court's Reasoning: 1. Quasi-Judicial Obligations: The Court observed that authorities exercising quasi-judicial powers must apply their minds to the facts and record justifiable reasons. An order affecting the rights of a party must "speak" for itself. 2. Natural Justice and Transparency: Referring to *Kranti Associates Pvt. Ltd. v. Masood Ahmed Khan*, the Court emphasized that recording reasons is a component of natural justice and "the soul of justice." It acts as a restraint on arbitrary exercise of power and facilitates judicial review. 3. Administrative Accountability: Citing *State of Punjab v. Bandip Singh*, the Court held that executive decisions must be composite and self-sustaining, containing all reasons that led to the conclusion. "Rubber-stamp" or "pretence" reasons do not satisfy the requirement of a valid decision-making process. Conclusion: Finding both the impugned punishment order and the appellate order to be non-speaking and devoid of reasoning, the High Court quashed both orders. The matter was remanded to the Disciplinary Authority to pass a fresh, reasoned order after providing the petitioner an opportunity for a personal hearing. Judgment: Petition allowed; orders quashed and remanded for fresh consideration.

The petitioner, an Assistant Manager, challenged two orders: a disciplinary order dated 28.12.2023 [Annexure P-2] and an appellate order dated 27.10.2025 [Annexure P-1].

The Disciplinary Authority had imposed a punishment of withholding one annual increment with cumulative effect (later described in the order as two increments for one year without cumulative effect) following a show-cause notice and electricity theft proceedings.

The petitioner contended that both the disciplinary and appellate orders were non-speaking, unreasoned, and failed to consider his specific explanations or the grounds raised in his appeal.

1. Whether the Disciplinary and Appellate Authorities, while exercising quasi-judicial powers, are mandated to pass reasoned and speaking orders.

2. Whether the impugned orders dated 28.12.2023 and 27.10.2025 are legally sustainable if they fail to reflect the application of mind to the facts and defenses raised by the petitioner.

Disciplinary and Appellate Authorities exercise quasi-judicial powers and must pass "speaking orders" that reflect an application of mind to relevant facts and circumstances.

Administrative decisions must be self-sustaining and not arbitrary, as established in State of Punjab v. Bandip Singh (2016) 1 SCC 724.

Reasons are the "lifeblood of judicial decision-making" and a component of natural justice and human rights, as per Kranti Associates Private Limited v. Masood Ahmed Khan (2010) 9 SCC 496.

The Court perused the text of the impugned orders and found them deficient in reasoning, observing that the Disciplinary Authority merely reiterated the proposed punishment without addressing the petitioner's point-wise reply or explaining why his explanation was unsatisfactory.

The Appellate Authority rejected the appeal by simply affirming the lower order without discussing the specific grounds of appeal.

Since these orders affect the rights of the party, the "face of the order" must speak so the affected party knows how their defense was considered.

The absence of cogent, clear, and succinct reasons rendered the orders "rubber-stamp" decisions, violating the principles of transparency and accountability required under the rule of law.

The matter was remanded to the Disciplinary Authority with a direction to pass a fresh, reasoned, and speaking order within three months, explicitly considering the petitioner’s explanation dated 09.10.2023 and providing him a personal hearing.