The Supreme Court of India has quashed the discharge of Pinky Meena from the Rajasthan Judicial Service, holding that the order violated principles of natural justice and lacked legal justification. The Court directed her immediate reinstatement with all consequential benefits except back wages.
The case arose from the dismissal of Pinky Meena, a probationary Civil Judge, by the High Court of Judicature for Rajasthan at Jodhpur. The Supreme Court set aside the discharge order dated May 29, 2020, and the preceding show cause notice dated February 17, 2020, citing procedural lapses and an absence of substantive misconduct during her judicial service tenure.
Background of the Case
Meena, who holds degrees in Arts, Education, Law (LL.B.), and a Master of Laws (LL.M.), joined the Education Department of Rajasthan as a Grade-II Teacher in 2014. In response to a 2017 recruitment notice, she applied for and was appointed as a Civil Judge in 2019, following her resignation from her teaching position.
Complaints were subsequently filed alleging that Meena obtained overlapping academic degrees in contravention of university regulations, failed to secure proper permissions for pursuing LL.M. while in government service, and did not disclose her prior employment in her judicial application documents.
Arguments from Both Sides
Meena’s counsel contended that:
- The alleged misconduct related to her tenure in the Education Department, not her judicial service.
- She resigned before her interview and was no longer a government servant at that time.
- Her probationary period was completed without blemish.
- The inquiry process was flawed as she was denied proper representation and was not provided the inquiry report.
The respondents argued that Meena pursued LL.B. and B.Ed. simultaneously in violation of Ordinances 168-A and 168-B of the University of Rajasthan, obtained an LL.M. without permission, and concealed her previous government employment, warranting her discharge under Rules 44 to 46 and Rule 14 of the Rajasthan Judicial Service Rules, 2010.
Court’s Analysis
The bench comprising Justices B.V. Nagarathna and Satish Chandra Sharma held:
- Misconduct allegations predated her judicial service and were not of a nature to justify discharge during probation.
- The omission to disclose prior government service was not a serious irregularity given that her resignation predated the interview.
- The inquiry process breached natural justice as it denied Meena an opportunity to effectively participate.
The Court emphasized that “non-disclosure of past government service cannot be a ground for discharging the appellant,” and that “capital punishment [i.e., termination] for a minor irregularity (omission)” was not justified.
It also observed the broader significance of inclusivity in the judiciary, stating: “The appellant has shown great perseverance by fighting societal stigmas and gaining a rich education that will ultimately benefit the judicial system and the democratic project.”
Final Judgment
Allowing the appeal, the Supreme Court quashed the show cause notice and discharge order. Meena is to be reinstated forthwith with all consequential benefits including seniority and notional pay fixation, except back wages. She is also to be treated as having successfully completed her probation and confirmed in service.
