The Telangana High Court has dismissed a writ petition filed by a former trainee Civil Judge challenging his discharge from judicial service, holding that his subsequent acquittal in a criminal case did not automatically invalidate the earlier decision taken on the ground of unsuitability during probation.
A Division Bench comprising Acting Chief Justice P. Sam Koshy and Justice Narsing Rao Nandikonda held that the discharge was an order of termination simpliciter (termination without imposing a disciplinary punishment), based on an overall assessment of the officer's conduct and suitability. Consequently, the protection available under Article 311 of the Constitution could not be invoked in the circumstances of the case.
Background
The petitioner, P. Satyanarayana Rao, was appointed as a Civil Judge (Junior Division) in September 2016 and was placed on probation. During his training at the Judicial Academy, a report was submitted alleging that he had behaved improperly while observing proceedings in the High Court on July 23, 2018, by engaging in loud conversations with another trainee judicial officer.
A second report concerned an alleged incident during practical field training at Yenkepally Village in August 2018. Separately, a criminal complaint was lodged against him, resulting in the registration of an FIR under various provisions of the Indian Penal Code and the SC/ST (Prevention of Atrocities) Act.
The petitioner was suspended and subsequently asked to explain why his probation should not be terminated. After considering his explanation, the Administrative Committee resolved to discharge him from service on November 5, 2018. The Government issued the consequential discharge order on December 31, 2018.
The petitioner challenged the decision, arguing that the discharge was punitive in nature and could not have been ordered without a regular departmental inquiry. He also relied on his acquittal in the criminal case by the trial court on February 26, 2024.
The High Court examined the vigilance records, reports from the Judicial Academy and the explanation submitted by the petitioner. It observed that the Administrative Committee had considered his overall conduct during training rather than relying on a single incident.
The Bench also considered the judgment of the Andhra Pradesh High Court that had set aside the discharge of another trainee judicial officer involved in the same set of proceedings. However, it held that the petitioner's suitability had to be independently examined on the basis of the material available in his individual case.
The Court observed:
"A judicial officer is expected to maintain the dignity, discipline and decorum commensurate with the office held by him. Such standards of conduct are not confined merely to the period during which the officer is actually presiding over the Court or discharging judicial functions on the Bench."
On the question of acquittal, the Bench clarified that a subsequent criminal court decision could not automatically change the nature of the earlier administrative assessment.
It further observed:
"The subsequent acquittal of the petitioner in the criminal case is a circumstance which may require separate consideration, but such subsequent development cannot, by itself, retrospectively convert the assessment of suitability made on the basis of the material available at the relevant point of time into a disciplinary finding of guilt."
The Court also found that the discharge order did not contain specific findings of misconduct or stigmatic allegations. The references to the petitioner's conduct were considered part of the assessment of his suitability for judicial service.
The Bench concluded that the allegations had served as the motive for assessing the petitioner's suitability and were not the foundation of a punitive order. It also noted that the petitioner had been given an opportunity to submit his explanation, which was considered by the Administrative Committee.
Finding no legal ground to interfere with the discharge proceedings, the Telangana High Court dismissed the writ petition.
The Court made no order as to costs.
Case Details:
Case Title: P. Satyanarayana Rao v. High Court of Telangana State and Others
Case Number: Writ Petition No. 10143 of 2019
Judges: Acting Chief Justice P. Sam Koshy and Justice Narsing Rao Nandikonda
Decision Date: 30 October 2026
