The Supreme Court of India has given its report in a crucial case concerning Ms. Mepung Tadar Bage, Member of the Arunachal Pradesh Public Service Commission (APPSC). The proceedings were initiated under Article 317(1) of the Constitution after the President of India made a reference seeking her removal over allegations of misbehaviour linked to the leakage of the Assistant Engineer (Civil) Mains Examination paper in August 2022.
Background of the Case
Ms. Bage was appointed as a member of the APPSC in August 2021. The controversy began when a candidate complained that the question paper for the AE (Civil) Mains Examination held on 26–27 August 2022 had been leaked in advance. An FIR was lodged, investigations were transferred from local police to the Special Investigation Cell (Vigilance) and later to the CBI. The CBI charge sheet identified the Deputy Secretary-cum-Deputy Controller of Examination, Taket Jerang, as the main accused in the paper leak. Ms. Bage was not named in the charge sheet.
Despite this, the State Government set up a High-Level Inquiry Committee, which pointed out lapses in the Commission’s standard operating procedures but did not specifically indict any member. On moral grounds, the Chairman of the APPSC resigned, while three other members also stepped down. Ms. Bage remained the only serving member and was later suspended when the matter was referred to the Supreme Court.
The President of India framed six charges against her, including:
- Failure to prevent the leak of the AE (Civil) Mains Examination paper.
- Collective responsibility for lapses in confidentiality and guidelines.
- Not ensuring updates to the Conduct of Examination Guidelines since 2017.
- Failure in her role as the member in charge of legal matters to advise against decisions that weakened examination integrity.
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The Court analysed the evidence, including the Inquiry Committee’s report and witness testimonies. It noted that:
“No specific act or omission constituting misbehaviour has been attributed to Ms. Mepung Tadar Bage in her individual official capacity.”
The Court emphasised that Article 317 of the Constitution requires a high threshold for removing a Public Service Commission member and that “misbehaviour” must be proven through direct and cogent evidence. In this case, there was no proof of her involvement in the leakage or negligence in her assigned duties.
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The Supreme Court held that the allegations against Ms. Bage were not established. It clarified that while the APPSC as an institution had procedural lapses, individual responsibility must be proven for removal under Article 317.
“The credibility of Public Service Commissions rests on the faith of the public, but removal of a member must be based on clear and specific evidence, not broad institutional failures.”
With this ruling, Ms. Mepung Tadar Bage stands cleared of the charges of misbehaviour, and the Court’s decision reinforces the constitutional safeguard that protects the independence of Public Service Commissions.
Case: In Re: Mepung Tadar Bage, Member, Arunachal Pradesh Public Service Commission
Applicant/Authority: President of India (Reference made to Supreme Court)
Respondent: Ms. Mepung Tadar Bage, Member, APPSC
