Writ courts will not reappraise disciplinary findings absent perversity, no evidence, or procedural violation.

The petitioner, Rajendra Singh, was appointed as Booth Level Officer for Booth No. 158, Magarda, District Harda, pursuant to an election-duty order dated 10 December 2013.

On 23 April 2014, the Naib Tahsildar complained that the petitioner, while performing election-related duties, was found under the influence of alcohol and had misbehaved with her. A panchnama was prepared and he was medically examined; the medical report recorded that he was under the influence of alcohol.

He was suspended and issued a charge-sheet dated 21 May 2014 alleging, inter alia, dereliction of election duties, intoxication, and misbehaviour with the Naib Tahsildar.

A departmental inquiry was conducted under Rule 14 of the M.P. Civil Services (Classification, Control and Appeal) Rules, 1966, during which witnesses were examined and the petitioner was permitted to participate and cross-examine them.

The disciplinary authority imposed the penalty of withholding one annual increment with cumulative effect on 2 May 2015, and the appellate authority dismissed his appeal on 23 February 2017.

Whether the departmental inquiry and consequential punishment were vitiated by violation of principles of natural justice or failure to follow the procedure prescribed under Rule 14 of the 1966 Rules?

Whether the discrepancy in the reference to Booth Nos. 158 and 159 invalidated the charges or caused prejudice to the petitioner?

Whether withholding one annual increment with cumulative effect was excessive, arbitrary, or disproportionate to the misconduct proved against the petitioner?

The Court applied Article 226 of the Constitution, under which judicial review of departmental proceedings is confined primarily to the legality of the decision-making process and not to re-appreciation of evidence as an appellate court.

Interference is warranted where findings are based on no evidence, are perverse, or where statutory procedure or principles of natural justice have been violated.

The Court applied Rule 14 of the M.P. Civil Services (Classification, Control and Appeal) Rules, 1966, governing regular departmental inquiries, and Rule 10, which recognises withholding of an annual increment with cumulative effect as a permissible penalty.

A procedural discrepancy will not vitiate disciplinary proceedings in the absence of demonstrated prejudice to the delinquent employee.

The Court found that the petitioner had been clearly informed of the charges, submitted a reply, participated in the regular inquiry, and was afforded an opportunity to cross-examine the departmental witnesses.

The panchnama, medical report, witness testimony, apology letter, and the petitioner’s own statement seeking pardon constituted material supporting the findings of misconduct, including intoxication and misbehaviour while performing election duty.

The Court held that the reference to Booth No. 159, despite the petitioner’s appointment at Booth No. 158, did not establish prejudice or affect his ability to defend himself and therefore did not invalidate the proceedings.

Given the seriousness of misconduct by a government servant engaged in election-related duties, the penalty authorised by Rule 10 was held neither excessive nor disproportionate.

Since the petitioner failed to demonstrate absence of evidence, perversity, procedural illegality, or denial of natural justice, no ground for interference under Article 226 was made out.

The writ petition was accordingly dismissed, and the punishment order dated 2 May 2015 and appellate order dated 23 February 2017 were left undisturbed.

No order as to costs was made.