The Madhya Pradesh High Court has dismissed the writ petition of former Civil Judge Mahendra Singh Taram, who challenged his dismissal from service for procedural irregularities in criminal cases. The Division Bench comprising Chief Justice Suresh Kumar Kait and Justice Vivek Jain held that the charges constituted grave misconduct and upheld the disciplinary authority’s decision to remove him from service.
Background
Mahendra Singh Taram was appointed as a Civil Judge Class-II on 29 July 2003. While posted at Niwas, District Mandla, a surprise inspection was conducted on 4 December 2012 by the District Judge (Inspection and Vigilance), Jabalpur Zone. The inspection revealed that he had acquitted accused persons in multiple criminal cases without preparing judgments and failed to draw order-sheets on several occasions.
Departmental Proceedings and Charges
A show-cause notice and articles of charge were issued on 11 December 2012. In his reply, Taram admitted the allegations and attributed the lapses to workload pressure and personal responsibilities. He also submitted an unconditional apology.
The Enquiry Officer, in a report dated 21 March 2014, recorded the following findings:
“In Cr.Case No.87/2006 State Vs. Krishna Kumar… the accused persons were acquitted only on the basis of order-sheet dated 26-11-12… but no further order-sheet was written by the petitioner.”
“On perusal of Cr.Case No.471/06… the same was decided vide Judgment dated 30.11.12, acquitting the accused persons whereas no judgment was written by the petitioner.”
“In Cr.Case No.216/06… the accused were acquitted but no judgment was prepared in this case.”
The officer concluded:
“The Enquiry Officer after scrutinising the matter came to the conclusion that the delivery of the judgment without writing it and adjourning the cases without drawing any order sheet by the petitioner amounts to grave misconduct.”
The Full Court accepted the findings and resolved to impose the penalty of removal from service under Rule 10(viii) of the M.P. Civil Services (Classification, Control & Appeal) Rules, 1966.
Petitioner’s Arguments
Taram’s counsel argued that the punishment was arbitrary and disproportionate. He cited the case of another judicial officer, Siddharth Sharma, who was awarded a lesser penalty — withholding of two increments with cumulative effect — for comparable lapses. He contended that such disparity violated Articles 14 and 16 of the Constitution.
Respondents’ Submissions
The counsel for the High Court and the State submitted:
“The enquiry of Shri Siddarth Sharma and petitioner Shri Mahendra Singh Taram are separate enquiries and have no connection with each other…”
They added:
“On perusal of the charge sheet of the petitioner… it is clear that all the charges related to acquittal of accused persons in criminal trials without writing any judgment.”
Relying on State of Tamil Nadu v. M. Mangayarkarasi (2019) 15 SCC 515, it was submitted that:
“Unless the penalty is found to be shockingly disproportionate to the charges which are proved, the element of discretion which is attributed to the employer cannot be interfered with.”
Court’s Decision
The Bench concluded:
“The petitioner failed to maintain absolute integrity and devotion to duty as judicial officer. Such acts of petitioner being unbecoming of a judicial officer amount to grave misconduct under Rule 3 of M.P. Civil Services (Conduct) Rules, 1965.”
Citing B.C. Chaturvedi v. Union of India (1995) 6 SCC 749, the Court reiterated that judicial review over disciplinary penalties is limited and courts cannot substitute the punishment unless it is shockingly disproportionate.
The plea for parity was rejected, noting that the case of Siddharth Sharma involved civil matters and was fundamentally different. The Court thus upheld the dismissal and dismissed the petition.
