In a significant legal development, the Supreme Court recently delivered a crucial judgment that emphasized the comprehensive examination of acquittal judgments in criminal proceedings when assessing their impact on parallel disciplinary actions against employees. The case revolved around Constable Ram Lal from the Rajasthan Armed Constabulary, accused of manipulating his date of birth for employment purposes.

The bench, comprising Justice JK Maheshwari and Justice KV Viswanathan, stressed the importance of considering the entire judgment in such cases. Notably, the Court overturned the disciplinary action leading to Ram Lal's dismissal, ordering his reinstatement and granting him back wages. This decision stemmed from a thorough analysis of the acquittal judgment in the criminal proceedings.

The accused constable faced both criminal charges under Section 420 of the Indian Penal Code, resulting in a three-year imprisonment sentence, and disciplinary proceedings initiated by the department. The Appellate Court acquitted him of the criminal charges, prompting Ram Lal to challenge his dismissal through a Civil Appeal in the Supreme Court.

The Court framed key issues for consideration, including the justification for the dismissal in the departmental inquiry and the impact of the criminal trial's acquittal on the disciplinary action. While highlighting that acquittal in criminal proceedings doesn't automatically warrant reinstatement, the Court underscored that alignment in charges, evidence, and circumstances could be considered during a judicial review.

The judgment acknowledged the limited authority of a writ court in reviewing disciplinary orders but emphasized the right to assess the legitimacy of the decision-making process. The Court found that the disciplinary authority failed to consider crucial evidence, leading to a breach of natural justice.

Moreover, the Court cautioned against superficial interpretations of terms like "benefit of doubt" and "honourably acquitted," emphasizing the need for substantive assessments. The acquittal, resulting from a meticulous scrutiny of evidence, indicated the prosecution's failure to establish charges.

The Court specifically highlighted the discrepancy between facts being 'disproved' and 'not proved.' In this context, it pointed out that the 10th standard mark sheet presented during the inquiry belonged to a different individual, distinct from the appellant, leading to the conclusion that the termination order and subsequent actions were illegal.

In line with its findings, the Supreme Court allowed the appeal, nullified the challenged order, and directed the reinstatement of Ram Lal. Additionally, the Court ordered the payment of 50% of back wages to the appellant, marking a significant legal precedent in cases involving the interplay of criminal acquittals and disciplinary proceedings.

Case: Ram Lal v State of Rajasthan & Ors,

CIVIL APPEAL NO. 7935 OF 2023
(Arising out of SLP (C) No. 33423 of 2018).

Click here to read/download judgment.