The Supreme Court of India, in its judgment dated 25 July 2025, set aside a Karnataka High Court order that had quashed departmental charge-sheets issued against R. Shankarappa, a retired Sub Divisional Engineer from the Department of Telecommunications (DOT).
The top court held that charge-sheets issued by a General Manager—an authority empowered to impose minor penalties—are valid even if they pertain to major penalty proceedings, under the Central Civil Services (Classification, Control and Appeal) Rules, 1965 (CCS CCA Rules).
Background of the Case
Shankarappa retired on 31 May 2018. He was earlier prosecuted by the CBI in two corruption cases:
- Bribery Case (CC No. 42/2003) – Accused of accepting ₹1 lakh bribe.
- Disproportionate Assets Case (CC No. 92/2003) – Alleged to have assets beyond his known income.
He was convicted in both cases, but the Karnataka High Court stayed his conviction and sentence in 2014. Meanwhile, departmental inquiries were initiated under Rule 14 of CCS CCA Rules via two charge-sheets dated 27.05.2006 and 01.12.2008.
Shankarappa repeatedly challenged these departmental actions. He filed six different applications before the Central Administrative Tribunal (CAT), Bengaluru, trying to stall the inquiry proceedings.
He later filed OA No. 170/00457/2021, arguing that the charge-sheets were void because they were issued by a General Manager who was not authorized to impose major penalties, and cited the Supreme Court’s ruling in Union of India vs. B.V. Gopinath (2014).
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“To declare that the proceedings initiated... are void-ab-initio for want of approval from the appointing authority.” — From OA No. 170/00457/2021
However, CAT dismissed his plea, stating that even an authority empowered to impose minor penalties can issue charge-sheets under Rule 14. The High Court disagreed and overturned CAT’s decision, citing B.V. Gopinath’s case.
The Supreme Court, led by Justices Sanjay Kumar and Satish Chandra Sharma, restored the CAT’s findings.
“An authority empowered to impose minor penalties can certainly initiate disciplinary proceedings even for major penalties.” — Supreme Court Bench
- Rule 13(2) of CCS CCA Rules permits initiation of proceedings for major penalties by an authority competent for minor ones.
- The General Manager (Telecom) acted within legal powers in issuing the charge-sheet.
- The High Court wrongly relied on B.V. Gopinath’s case, which involved a Finance Ministry-specific office order, not applicable to DOT.
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“In the present case, there is no such office order... and the statutory provisions do not require approval from Member, Telecom Commission.” — SC Clarifies
The Supreme Court allowed the appeal filed by the Union of India and:
- Set aside the Karnataka High Court's order dated 18.11.2022.
- Upheld the validity of the charge-sheets dated 27.05.2006 and 01.12.2008.
- Confirmed CAT’s decision dismissing Shankarappa’s application.
Case: Union of India & Ors. vs. R. Shankarappa
(Civil Appeal arising out of SLP (Civil) No. 7149 of 2023)