The Supreme Court, in a recent judgment, declared that when charges, evidence, witnesses, and circumstances in both disciplinary and criminal proceedings are substantially the same, the continuation of the disciplinary punishment after a criminal acquittal is "unjust, unfair, and oppressive."

“Upholding findings in departmental proceedings would be unjust, unfair, and oppressive where identical charges have led to an acquittal in a criminal trial,” said the bench of Justices Dipankar Datta and Prashant Kumar Mishra.

The case involved Maharana Pratap Singh, a constable in the CID Dog Squad, who was arrested in 1988 on extortion charges and later dismissed from service. A departmental inquiry proceeded despite his request to wait until the criminal trial ended, as he feared revealing his defense early. Eventually, he was dismissed in 1996.

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While he was initially convicted, the Sessions Court later acquitted him in 1996, observing that the prosecution had "miserably failed to prove its case" as both key witnesses—PW-1 and PW-2—refused to identify him in court.

Despite this, his dismissal from service remained in effect. He challenged the dismissal, and although a Single Judge ruled in his favor, the High Court Division Bench reversed the decision. The matter then reached the Supreme Court.

“The departmental records were withheld by the State, which suggests deliberate concealment of illegalities in the proceedings,” the Court noted, drawing an adverse inference against the State.

The Court observed that:

• The charges were vague and lacked specific details, violating Rule 55 of the Civil Services Rules.
• The informant, whose complaint led to the proceedings, was never examined.
• The key witness, PW-1, was not cross-examined, denying the appellant a fair trial.
• PW-2, in both the inquiry and criminal trial, failed to support the case against the appellant.

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“Due process was not followed. The disciplinary inquiry was flawed from the outset and violated natural justice,” the Court stated firmly.

Considering the appellant’s age and the years lost due to wrongful dismissal, the Court declined reinstatement but awarded ₹30 lakh as compensation, along with ₹5 lakh in costs.

“We conclude beyond any doubt that the dismissal was unjustified and cannot be allowed to stand,” the judgment emphasized.

Case Details: MAHARANA PRATAP SINGH v. THE STATE OF BIHAR & ORS.