Supreme Court Clears APPSC Member of Wrongdoing, Orders Immediate Reinstatement with Full Benefits
The Supreme Court of India delivered a significant judgment on August 28, 2025, in a case that centered around allegations of misconduct against Ms. Mepung Tadar Bage, a member of the Arunachal Pradesh Public Service Commission (APPSC). The Court’s ruling, delivered by Justices J.K. Maheshwari and Aravind Kumar, decisively cleared the respondent of all charges and directed the revocation of her suspension. This decision is expected to reaffirm the constitutional protections afforded to members of Public Service Commissions under Article 317 of the Constitution of India.
The case originated after the leakage of question papers during the 2022 APPSC Mains Examination. Following widespread public and political pressure, the Governor of Arunachal Pradesh made a reference to the President of India seeking an inquiry under Article 317(1), alleging misbehaviour by Ms. Bage in her capacity as a member of the Commission. The President then referred the matter to the Supreme Court for investigation and recommendation.
Background of the Case
The allegations against Ms. Mepung Tadar Bage included her supposed failure to maintain confidentiality, inability to prevent the question paper leak, and her alleged inaction in framing new examination guidelines that might have prevented the irregularities. She was also accused of failing to advise the Commission against keeping certain punishments in abeyance for candidates who had engaged in unfair practices. However, during the proceedings, no direct evidence was produced linking her to any act of misconduct or negligence.
The petitioner argued that as a member responsible for legal and judicial work, Ms. Bage had an obligation to ensure that the confidentiality and integrity of the Commission were preserved. The respondent, however, through her written and oral submissions, categorically denied any wrongdoing. She asserted that she was neither involved in paper setting nor in any part of the examination process that could have led to the leak. She maintained that the decision to suspend the new guidelines and the punishment policy was taken collectively by the Commission, and no individual member, including herself, could be held responsible.
Arguments Before the Court
The petitioner’s representatives argued that Ms. Bage, being an integral part of the APPSC, bore collective responsibility for the Commission’s failures. They emphasized that her inaction in pushing for reform and her alleged failure to ensure confidentiality amounted to ‘misbehaviour’ under Article 317(1). They also submitted that the public trust in the Commission had been eroded and that such constitutional office bearers should be held to the highest standards of integrity and vigilance.
The respondent’s counsel, on the other hand, contended that the allegations were baseless and politically motivated. They emphasized that there was no specific act or omission attributable to Ms. Bage that could amount to misconduct. The defense further pointed out that the alleged irregularities had their roots in systemic deficiencies within the APPSC dating back to 2017, long before the respondent joined in 2021. Therefore, expecting her to rectify years of institutional shortcomings was unreasonable and contrary to the principle of individual liability.
Court’s Analysis and Findings
The Supreme Court examined the scope of ‘misbehaviour’ under Article 317(1) and drew upon a series of precedents, including Reference under Article 317(1) of the Constitution, In re (1983), Ram Ashray Yadav (Dr.) (2000), and Mehar Singh Saini (2010). The Court reiterated that ‘misbehaviour’ encompasses conduct that may erode public confidence in the office, but not every act of negligence or error in judgment amounts to such misbehaviour.
In a crucial observation, the bench noted, “When there is no evidence linking the present respondent to the leakage of the question paper of the Mains Examination, summarily holding her responsible and seeking to remove her from office on the pretext of not maintaining confidentiality in the work of the Commission, it would further erode the roots of the constitutional intent of Article 317 to protect the Members of the Public Service Commission from political pressure.”
The Court emphasized that the primary objective of Article 317 was to safeguard the independence and integrity of Public Service Commissions. It held that the inquiry reports and witness statements failed to establish any connection between the respondent and the alleged irregularities. Moreover, the Court observed that none of the departmental witnesses testified that she was involved in the examination process or that her conduct led to the leakage of the question papers.
Referring to the constitutional principle of collective responsibility, the bench observed that holding one member accountable for the actions of the entire Commission would be contrary to natural justice. The judgment stated, “The actions alleged against the respondent do not meet the threshold of ‘misbehaviour’, rather, they do not even meet the threshold of ‘lapse’ which has a lower threshold.”
The Supreme Court’s Final Decision
After a detailed evaluation of all charges, the Court concluded that the allegations were not supported by any cogent evidence. The report observed, “The reference made by the Hon’ble President of India for the charges as alleged are not based on specific allegations against the respondent Ms. Mepung Tadar Bage in her individual or official capacity. The allegations which are general in nature have not even been substantiated by bringing any cogent evidence before us.”
The judgment further read, “As we have found that the charge of misbehaviour has not been proved against the respondent, the points of determination jointly framed by the parties are answered accordingly. In view of the foregoing, the inescapable conclusion on the allegations of charges as made in the reference is that the allegations have not been proved.”
Accordingly, the Court recommended to the President of India that the charges against Ms. Bage be dismissed. It also directed that her suspension be revoked with immediate effect and that she be entitled to all consequential and monetary benefits arising from the wrongful suspension.
Implications of the Judgment
This verdict has far-reaching implications for the autonomy of constitutional bodies such as the Public Service Commissions. By reaffirming that members cannot be held personally liable for institutional shortcomings unless there is clear evidence of misconduct, the Court has reinforced the protective intent of Article 317. It serves as a reminder that the independence of these institutions must be shielded from political interference or undue influence.
In essence, the Court’s decision restores faith in the principle that constitutional office bearers are entitled to due process and fairness. It also underscores the importance of evidence-based proceedings before branding an act as ‘misbehaviour.’ The reinstatement of Ms. Mepung Tadar Bage symbolizes not only her personal vindication but also the judiciary’s commitment to upholding the autonomy and dignity of public institutions.
Petitioner Name: President of India.Respondent Name: Ms. Mepung Tadar Bage.Judgment By: Justice J.K. Maheshwari, Justice Aravind Kumar.Place Of Incident: Arunachal Pradesh.Judgment Date: 28-08-2025.Result: dismissed.
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