Punjab & Haryana High Court Dismisses Appeal by Jail Clerk, Upholds Disciplinary Action for Dereliction of Duty During NHRC Visit

Case Name: Narinder Singh v. State of Haryana and Others
Date of Judgment: October 14, 2025
Citation: RSA-602-2022
Bench: Hon’ble Mrs. Justice Sudeépti Sharma

Held: The Punjab & Haryana High Court dismissed a second appeal filed by a Jail Department employee challenging disciplinary action for negligence during an inspection by the National Human Rights Commission (NHRC). Justice Sudeépti Sharma held that civil courts cannot sit in appeal over the findings of disciplinary authorities or substitute their conclusions regarding punishment. The Court ruled that the inquiry against the employee had been conducted in compliance with the principles of natural justice and that the penalty imposed was proportionate to the misconduct proved.

Summary: The appellant, Narinder Singh, a clerk with the Jail Department since 1988, was served with a chargesheet on January 20, 2004, alleging that he failed to satisfactorily respond to questions posed by NHRC officials regarding prisoners’ wages during an inspection on October 17, 2003, and that he was absent without permission on October 18, 2003, when the NHRC Chairman visited the Central Jail, Ambala. Following an inquiry, his one annual increment was stopped without cumulative effect by order dated November 10, 2005. His departmental appeal was rejected, and a subsequent civil suit challenging the punishment succeeded before the trial court but was reversed in appeal by the District Judge, Ambala, on January 18, 2021.

Justice Sharma noted that the District Judge’s reasoning was consistent with Supreme Court precedents, including State of Punjab v. Surjit Singh Conductor (1996) 2 SCT 609 and R.R. Parekh v. High Court of Gujarat (2016) 4 SCT 102, holding that disciplinary proceedings are governed by the preponderance of probabilities, not proof beyond reasonable doubt, and that courts should not re-evaluate evidence unless findings are perverse or unsupported by material. The Court further observed that the inquiry records (Ex.D2–D7) showed that the principles of natural justice were followed and that the punishment order was validly issued by the competent authority.

Decision: The High Court found no illegality or perversity in the lower appellate court’s judgment and upheld the disciplinary action. The Regular Second Appeal was accordingly dismissed as devoid of merit.