Suspension revocation is not mandatory despite prolonged duration where grave charges and public interest necessitate continued exclusion from service.

The respondent, a Deputy Inspector General of Registration, was placed under suspension following his arrest on May 29, 2024, in connection with Crime No. 2 of 2022.

He was remanded to judicial custody for over 48 hours.

The allegations involved serious misconduct, specifically the tampering of original index documents within the Registration Department based on forged records to register bogus documents.

While a charge sheet was filed in the criminal case, the respondent obtained an interim stay of those proceedings from the High Court.

Simultaneously, departmental proceedings were initiated, and a charge memorandum was issued on May 29, 2026.

The respondent challenged the suspension in W.P. No. 38990 of 2025, and the Writ Court set aside the suspension order on November 25, 2025.

The State preferred this intra-court appeal against that revocation.

1. Whether the order of suspension was legally infirm given the respondent's detention in judicial custody exceeding 48 hours.

2. Whether prolonged suspension necessitates revocation regardless of the gravity of charges and public interest.

3. Whether the revocation of suspension of a high-ranking official facing serious fraud allegations is detrimental to public interest and the integrity of departmental inquiries.

The court applied Rule 17(e)(1) and (2) of the Tamil Nadu Civil Services (Discipline and Appeal) Rules, which mandate suspension for detention exceeding 48 hours and allow it during pending criminal investigations or departmental inquiries.

It relied on the Full Bench decision in P. Kannan v. The Commissioner for Municipal Administration, holding that the Ajay Kumar Choudhary precedent does not set an absolute three-month limit on suspension and that each case must be decided on its facts, gravity of charges, and rules.

The court applied principles from Union of India v. Ashok Kumar Aggarwal, which establish that suspension is an interim measure to keep a delinquent "out of the mischief range" and that courts should generally not interfere with the disciplinary authority's domain unless the order is mala fide.

The Court reasoned that the initial suspension was valid under Rule 17(e) because the respondent’s custody exceeded 48 hours.

It rejected the argument for revocation based solely on the duration of the suspension (one year and nine months), emphasizing that the gravity of the offense—tampering with state land records—outweighs the passage of time.

The Court noted that the respondent himself had stalled the criminal trial via an interim stay, thus he could not solely plead delay.

Critically, the Court observed that as a Deputy Inspector General controlling eleven districts, the respondent’s reinstatement could prejudice the "free and fair" inquiry, as subordinate officers (Sub-Registrars) are custodians of the documents currently under investigation.

The Court concluded that "public interest" necessitates keeping the respondent away from official functions to prevent potential tampering or influence over witnesses.

The High Court allowed the appeal and set aside the Writ Court’s order dated November 25, 2025.

The appellants were directed to conclude the departmental enquiry as expeditiously as possible, with a further direction to the respondent to cooperate without seeking "unnecessary adjournments on flimsy grounds"; the Government retains the liberty to review the suspension at an appropriate time.