Supreme Court Overturns Constable’s Dismissal, Awards ₹35 Lakh Compensation for Procedural Lapses

The Supreme Court of India recently delivered a significant judgment in the case of Maharana Pratap Singh vs. The State of Bihar & Ors., setting aside a 1996 dismissal order against a police constable and awarding him ₹35 lakh in compensation. The judgment, dated April 23, 2025, was delivered by a bench comprising Justice Dipankar Datta and Justice Prashant Kumar Mishra, highlighting serious procedural lapses in the disciplinary proceedings.

The case involved Maharana Pratap Singh, a constable in Bihar’s Crime Investigation Department (CID) who was dismissed in 1996 following allegations of extortion and cheating. The Supreme Court found multiple violations of natural justice in the disciplinary process, including denial of cross-examination rights and reliance on vague charges.

The Court observed: “Based on the foregoing discussion, the version of the appellant that the charges drawn up against him were vague, indefinite, unspecific and lacked essential particulars has to be accepted.” This finding was based on the Court’s inability to examine the original chargesheet as the Bihar government failed to produce the departmental file despite specific directions.

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The judgment extensively discussed the principles of natural justice in disciplinary proceedings, citing precedents like Union of India v. H.C. Goel and G.M. Tank v. State of Gujarat. The Court emphasized that while departmental inquiries don’t require strict adherence to evidence rules, they must maintain basic fairness standards.

Key findings included:

1. The charges were vague and lacked material particulars, violating Rule 55 of the Civil Services Rules
2. The appellant was denied the right to cross-examine a key witness (PW-1)
3. The inquiry officer made assumptions without evidence, particularly regarding witness testimony
4. The complainant whose written statement initiated proceedings was never examined
5. The criminal case on similar charges ended in acquittal on merits

The Court noted: “Law is also well-established that the standards for establishing a guilt in disciplinary proceedings differ from those applicable to criminal proceedings. However, it is equally true that departmental authorities are obligated to provide a fair opportunity to the parties involved.”

While setting aside the dismissal, the Court declined to order reinstatement as the appellant was now 74 years old. Instead, it awarded ₹30 lakh as compensation for lost service benefits and ₹5 lakh as costs, noting that the appellant had about 14-15 years of service remaining when dismissed in 1996.

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This judgment reinforces the importance of procedural fairness in disciplinary actions, particularly for government employees, while balancing practical considerations of relief when reinstatement isn’t feasible due to passage of time.

Petitioner Name: Maharana Pratap Singh.
Respondent Name: The State of Bihar & Ors..
Judgment By: Justice Dipankar Datta, Justice Prashant Kumar Mishra.
Place Of Incident: Patna, Bihar.
Judgment Date: 22-04-2025.
Result: allowed.

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