Quasi-judicial orders passed by disciplinary and appellate authorities must be speaking orders containing valid and justifiable reasons.

The petitioner, an Assistant Manager/Junior Engineer, was served a charge-sheet on April 6, 2016, and a supplementary charge-sheet on September 2, 2010

The petitioner contended that several requested documents necessary for his defense, such as log-sheet registers and specific distribution formats, were not supplied

Following an inquiry, the Disciplinary Authority passed an order on March 30, 2017, imposing a major punishment of withholding one increment with cumulative effect

The petitioner’s subsequent appeal was rejected by the Appellate Authority on July 1, 2017

The petitioner challenged these orders under Article 226 of the Constitution of India, primarily on the grounds that they were non-speaking and unreasoned

During the pendency of the matter, the petitioner retired on June 30, 2025

1. Whether the orders passed by the Disciplinary and Appellate Authorities were "speaking orders" that demonstrated an objective application of mind to the facts and defense

2. Whether the failure of quasi-judicial authorities to record specific reasons for imposing and upholding a punishment vitiates the decision-making process

The court applied the principles of natural justice and the requirement of quasi-judicial authorities to pass "speaking orders"

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

The court further cited Ram Kishun v. State of U.P. (2012), establishing that decisions must not be capricious or arbitrary but informed by reasons

Kranti Associates Pvt. Ltd. v. Masood Ahmed Khan (2010), which characterized the recording of reasons as an indispensable component of the decision-making process and human rights

The Court reviewed the text of the Disciplinary Authority’s order and found it merely stated that the petitioner’s reply contained no facts and concluded the punishment was "justifiable" without addressing the merits of the defense or the specifics of the evidence

Similarly, the Appellate Authority’s order was found to be a summary rejection that failed to consider the specific grounds raised in the appeal, relying instead on a vague assertion of "sympathetic consideration"

The Court reasoned that since these authorities exercise quasi-judicial powers, they are legally obligated to record justifiable grounds to ensure the affected party knows how their case was considered

Relying on the Kranti Associates doctrine, the Court noted that an order must not be like the "inscrutable face of a sphinx" but must demonstrate through reasoning that all relevant factors were objectively considered

The Court set aside both orders and directed the respondents to provide all consequential benefits to the petitioner within three months

Noting the petitioner’s age (64) and retirement on June 30, 2025, the Court expressly denied the respondents any liberty to take fresh action against the petitioner

The petition was disposed of with these directions