Court upholds misconduct findings on two charges but finds punishment disproportionate; disciplinary authority’s reversal of inquiry officer’s findings on other charges quashed for lack of independent evidence
In a significant judgment delivered on August 18, 2026, the Telangana High Court (Division Bench comprising Justices P. Sam Koshy and Narsing Rao Nandikonda) partially allowed a writ petition filed by Jacob Mudi, a probationary Junior Civil Judge, challenging his compulsory retirement imposed by the State of Andhra Pradesh on charges of misconduct.
Jacob Mudi was initially appointed as a Junior Civil Judge after completing his first phase of training at the Andhra Pradesh Judicial Academy. During his posting at Gurazala, Guntur District, he issued several judicial orders and show cause notices against police officials for lapses in investigation and dereliction of duty. This led to strained relations with police personnel, culminating in an incident on March 18, 2014, where Mudi’s official vehicle was stopped at an election check post, allegedly followed by rude and threatening behavior from him towards the police officers.
The disciplinary proceedings against Mudi included six Articles of Charge alleging grave misconduct under Rule 3 of the Andhra Pradesh Civil Services (Conduct) Rules, 1964. A departmental inquiry found Charges 1 and 2, relating to rude and discourteous conduct towards police personnel and obstruction of their duties, proved. However, Charges 3 to 6, which involved allegations of wrongful restraint and illegal detention of toll plaza officials, were not proved due to lack of corroborative evidence.
The disciplinary authority disagreed with the inquiry officer’s findings on Charges 3 to 6, asserting they were proved, and imposed the major penalty of compulsory retirement under Rule 9(8) of the Andhra Pradesh Civil Services (CCA) Rules, 1991. Mudi challenged this order before the Telangana High Court.
The Court’s detailed analysis noted that the disciplinary authority failed to produce any independent material or cogent reasons to justify overriding the inquiry officer’s findings on Charges 3 to 6. The Court set aside the disciplinary authority’s conclusions on these charges, thereby restoring the inquiry officer’s original finding that Charges 3 to 6 were not proved.
Regarding Charges 1 and 2, the Court upheld the inquiry officer’s findings, as they were supported by consistent oral and documentary evidence, including testimonies of police officials and statements recorded during the preliminary inquiry.
However, the Court underscored that Mudi was a young judicial officer serving his first posting after initial training and still on probation at the time of the incident. While his conduct fell short of the high standards of dignity, restraint, and propriety expected of judicial officers both on and off the bench, the Court found that the misconduct did not involve corruption, dishonesty, moral turpitude, or abuse of office for personal gain.
The Court emphasized the fundamental principle that the punishment must be proportionate to the proven misconduct. It held that compulsory retirement was an unduly harsh and shockingly disproportionate penalty for the misconduct established under Charges 1 and 2.
Applying the principle of proportionality, the Court set aside the compulsory retirement order and directed the respondents to reinstate Mudi without back wages for the period of absence from service since the retirement order. The petitioner’s seniority was to be fixed from the date of reinstatement, and he was directed to complete the remaining training.
The judgment reiterates the high standards of ethical conduct required of judicial officers, highlighting that they must maintain dignity and impartiality at all times. Simultaneously, it serves as a caution that disciplinary measures must be fair, just, and commensurate with the gravity of misconduct.
This ruling draws upon precedents from the Supreme Court and various High Courts, including the principles laid down in Krishna Prasad Verma v. State of Bihar (2019), Ishwar Chand Jain v. Punjab & Haryana High Court (1988), and recent judgments safeguarding the rights of probationary judicial officers against disproportionate disciplinary action.
Bottom Line:
Disciplinary proceedings against a judicial officer - Findings of Inquiry Officer and disciplinary authority - Articles of Charge Nos.1 and 2 upheld; Articles of Charge Nos.3 to 6 set aside due to lack of independent material or cogent reasoning for disagreement - Punishment of compulsory retirement held disproportionate to misconduct established - Reinstatement ordered with "no work, no pay" for the intervening period.
Statutory provision(s): Article 226 of the Constitution of India, Andhra Pradesh Civil Services (Conduct) Rules, 1964 (Rule 3), Andhra Pradesh Civil Services (Classification, Control and Appeal) Rules, 1991 (Rule 9(8))
Jacob Mudi v. State of Andhra Pradesh, (Telangana)(DB) : Law Finder Doc Id # 2971979
