The Supreme Court of India recently delivered an important judgment stating that a public servant’s acquittal in a criminal case does not automatically halt departmental proceedings against them. The court emphasized that the standard of proof in criminal trials and disciplinary inquiries is different, making it possible for an inquiry to continue even after an acquittal.
In a criminal trial, the prosecution must prove the accused’s guilt beyond a reasonable doubt. However, in a departmental inquiry, the case is assessed based on the principle of “preponderance of probabilities,” meaning a lower standard of proof is required. Due to this distinction, an acquittal in a criminal court does not automatically grant reinstatement to a dismissed public servant.
"A disciplinary proceeding is not a criminal trial. The standard of proof required is that of preponderance of probability and not proof beyond a reasonable doubt." – Supreme Court
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Case Background
The case revolved around an Assistant Engineer (Civil) from the Airports Authority of India (AAI), who was accused of corruption. He was convicted by the CBI Court but later acquitted by the Calcutta High Court due to lack of sufficient evidence.
Despite his acquittal, AAI initiated fresh disciplinary proceedings, leading to his dismissal from service. The High Court’s Division Bench later overturned this dismissal, prompting AAI to challenge the decision in the Supreme Court.
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The Supreme Court upheld the dismissal of the employee, ruling that an acquittal in a criminal case does not prevent an employer from conducting a disciplinary inquiry. The bench, comprising Justices JK Maheshwari and Sandeep Mehta, noted:
"The High Court made a serious error by equating the standard of proof in criminal trials with that in departmental inquiries. While criminal cases require proof beyond a reasonable doubt, disciplinary proceedings only require evidence based on the balance of probabilities."
Additionally, the court clarified that disciplinary authorities are not obligated to record detailed reasons while imposing punishment, as long as they rely on the findings of the inquiry officer.
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Different Standards of Proof: Acquittal in a criminal case does not mean a clean chit in a departmental inquiry.
No Automatic Reinstatement: An employee dismissed based on a disciplinary inquiry cannot demand reinstatement solely on the basis of acquittal in court.
Limited Judicial Review: Courts should not interfere with disciplinary inquiries unless there is a clear violation of legal procedures.
Departmental Authority’s Discretion: The employer has the right to take action based on available evidence, even if a criminal court did not find sufficient proof for conviction.
