Court Upholds That Erroneous Quasi-Judicial Decisions Alone Cannot Lead to Disciplinary Action Without Evidence of Misconduct
In a significant judgment, the Rajasthan High Court, presided over by Justice Mukesh Rajpurohit, has quashed the disciplinary proceedings and the penalty of permanent withholding of 100% pension imposed on Fateh Rai Soni, a retired officer of the Rajasthan Administrative Service. The judgment, delivered on August 5, 2026, emphasized that disciplinary proceedings against an officer exercising quasi-judicial powers cannot be sustained solely on an allegedly erroneous decision unless there is evidence of misconduct, such as mala fides, corruption, or dishonest intent.
The case arose from a quasi-judicial order passed by Soni in 2002 while serving as Officer-in-Charge during the Prashasan Gaon Ke Sang Abhiyan. The disciplinary proceedings were initiated on the day of his retirement, 15 years later, alleging that he had wrongly granted khatedari rights over pasture land. However, no allegations of corruption or mala fides were made. The court found that the proceedings sought to reopen a quasi-judicial determination that had attained finality, which is impermissible without evidence of misconduct.
The High Court highlighted procedural irregularities in the departmental enquiry, including denial of access to essential documents and failure to summon key witnesses, which vitiated the fairness of the proceedings. The court also noted the unexplained delay in initiating the proceedings, which prejudiced the petitioner.
Justice Rajpurohit ruled that the punishment of withholding the entire pension was disproportionate and arbitrary, as it lacked any finding of grave misconduct. The court ordered the restoration of Soni's pension and directed the respondents to disburse the arrears within two months.
This judgment reinforces the principle that judicial or quasi-judicial officers should not face disciplinary action for decisions made in good faith without malice or corruption, ensuring judicial independence and integrity.
Bottom line:-
Disciplinary proceedings against an officer exercising quasi-judicial powers cannot be sustained merely because of an erroneous judicial decision unless accompanied by evidence of misconduct such as mala fides, corruption, or dishonest intent.
Statutory provision(s): Rajasthan Civil Services (Classification, Control and Appeal) Rules, 1958, Rajasthan Civil Services (Pension) Rules, 1996, Section 88 of the Rajasthan Tenancy Act, 1955, Article 226 of the Constitution of India, Article 311 of the Constitution of India.
Fateh Rai Soni v. State of Rajasthan, (Rajasthan) : Law Finder Doc id # 2960865
