Quasi-judicial orders passed by disciplinary and appellate authorities must be reasoned speaking orders to be legally sustainable.

The petitioner, a Junior Engineer at the Sheopur Rural Distribution Centre, was served a show-cause notice on September 19, 2009

He submitted his reply on August 21, 2010; however, the Disciplinary Authority had already issued a punishment order on August 17, 2010—three days prior to receiving the reply—withholding two annual increments without cumulative effect

The petitioner appealed to the Appellate Authority, which partially modified the punishment on January 12, 2011, reducing it to the withholding of one annual increment for two years without cumulative effect

The petitioner challenged these orders under Article 226 of the Constitution of India, contending they were non-speaking and failed to consider the grounds raised in his defense

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

2. Whether the impugned orders, passed without considering the petitioner's reply and grounds of appeal, were legally sustainable

The Court applied the principle that authorities exercising quasi-judicial powers must pass "speaking orders" that demonstrate an objective application of mind to the facts

It relied on State of Punjab v. Bandip Singh (2016) 1 SCC 724, which mandates that administrative or executive decisions must be self-sustaining and disclose all prevailing reasons

It further invoked the principles from Kranti Associates Pvt. Ltd. v. Masood Ahmed Khan (2010) 9 SCC 496, which established that recording reasons is an indispensable component of natural justice and the "lifeblood" of judicial decision-making

The Court observed that the Disciplinary Authority issued the punishment order before even receiving the petitioner’s reply, indicating a total lack of application of mind and a failure to exercise due diligence

Upon perusing the appellate order, the Court found it to be non-speaking as it failed to address the specific facts and grounds raised by the petitioner in the appeal

The Court held that for a quasi-judicial order to be valid, the "face of the order must speak," ensuring the affected party understands how their defense was considered

Drawing from Kranti Associates, the Court reasoned that the requirement to record reasons is a component of human rights and fairness, and an order lacking such reasons is arbitrary and capricious

The Respondents were directed to grant the petitioner all consequential benefits within three months from the receipt of the certified copy of the order

Notably, as the petitioner had already retired, the Court explicitly declined to grant the respondents liberty to initiate any further action against him

The petition was disposed of accordingly