Reduction in rank for proved police misconduct warrants no interference absent shocking disproportionality.

The applicant, an Inspector of Police and Station House Officer at Karaikal, faced three disciplinary charges: failure to register a complaint, failure to ensure accused persons complied with court bail conditions and report their non-compliance, and failure to take action against two suspects allegedly handed over with ganja.

After an inquiry in which 14 witnesses were examined and 29 documents marked, all charges were found proved.

The Disciplinary Authority reduced the applicant in rank to Sub-Inspector; the Appellate Authority rejected his appeal.

The applicant challenged both orders, alleging, among other things, that the findings were unsupported by evidence, the appeal was rejected without proper consideration, and the penalty was disproportionate.

1. Whether the disciplinary findings or procedure disclosed a ground for judicial interference, including perversity, no evidence, or breach of natural justice.

2. Whether reduction in rank to Sub-Inspector was shockingly disproportionate to the proved misconduct.

Under Section 19 of the Administrative Tribunals Act, 1985, the Tribunal may review the challenged service orders, but judicial review in disciplinary matters is limited: it does not permit the Tribunal to reappraise the evidence or substitute its view for that of the disciplinary authority, except where, for example, there is a procedural or legal defect, a finding is unsupported by evidence, or the punishment is shockingly disproportionate.

The Tribunal relied on State of Uttar Pradesh v. Raj Kishore Yadav, (2006) 5 SCC 673, and Union of India v. Upendra Singh, (1994) 3 SCC 357, concerning those limits.

It also referred to Lalita Kumari v. Government of Uttar Pradesh, (2014) 2 SCC 1, for the requirement to register an FIR where information discloses a cognizable offence, and State of Punjab v. Ram Singh (Ex-Constable), (1992) 4 SCC 54, on misconduct and discipline in the police force.

The Tribunal found that the applicant had received an opportunity to defend himself, including a personal hearing, and that no procedural infirmity warranting intervention had been established.

Considering the charges found proved, the applicant’s position as an Inspector and Station House Officer, and the standards of responsibility expected of a police officer, it concluded that the misconduct was not a minor or technical lapse and that the reduction in rank was not shockingly disproportionate.

It found no established perversity, breach of natural justice, or other basis for disturbing the disciplinary and appellate orders.

It dismissed the Original Application and made no order as to costs.