SC reinstates U.P. HJS officer; disciplinary action can’t hinge on outcomes alone
Case name: Sadhna Chaudhary v. State of U.P. & Anr.
Date of Order: 06 March 2020
Citation: Civil Appeal No. 2077 of 2020 (arising out of SLP (C) No. 8550 of 2019)
Bench: S.A. Bobde, CJI; B.R. Gavai, J.; Surya Kant, J.
Held: Disciplinary control over judicial officers targets the decision-making process, not the end result of their judgments. Where the charge is premised only on allegedly “shocking” outcomes, and there is no specific allegation or proof that the process was tainted by extraneous considerations or gratification, punishment cannot be sustained—especially when one of the impugned awards has since been affirmed and even enhanced by superior courts. A misconduct case built solely on outcomes collapses when the foundation does not survive.
Summary: The appellant, a judicial officer who entered service in 1975 and was promoted to the Higher Judicial Service in 1987, was dismissed in 2006 after an administrative inquiry into two land-acquisition references she had decided at Ghaziabad. The charge-sheet criticized the steep enhancement of compensation and reliance on compromise deeds, treating the end results as indicative of improper conduct; the High Court upheld the dismissal, reading the outcomes as suggestive of extraneous influence. Allowing the appeal, the Supreme Court reiterated that judges are accountable for how they decide, not merely for what they decide. Integrity standards are exacting, but suspicion is not proof; absent pleading and proof of a vitiated process such as evidence of gratification, identified external pressure, or procedural impropriety discipline cannot rest on the final figures alone. The Court noted that in one of the very references relied on for punishment, appellate scrutiny had entered the merits and enhanced compensation, undermining the premise that the appellant’s orders were per se aberrant. As the entire disciplinary case was anchored only to judicial outcomes rather than a demonstrably tainted process, it could not stand.
Decision: Appeal allowed. The High Court’s judgment and the State’s dismissal order dated 17.01.2006 are set aside. The appellant is entitled to reinstatement with consequential and retiral benefits. No order as to costs.