In a sharp rebuke to the Madhya Pradesh government, the Supreme Court on Wednesday struck down a government order that had allowed Indian Administrative Service (IAS) officers to review the performance appraisal reports of Indian Forest Service (IFS) officers, terming the move “contemptuous” and in clear violation of the Court’s earlier directives.
A bench comprising Chief Justice of India D.Y. Chandrachud (correction: CJI B.R. Gavai as per actual case) and Justice Augustine George Masih ruled that the June 29, 2024 government order (GO) was contrary to the apex court’s binding directions issued on September 22, 2000. That earlier order had stipulated that the reporting authority for IFS officers must be an immediate superior within the forest department, up to the rank of Additional Principal Chief Conservator of Forests.
IAS Officers Cannot Be Reviewing Authority for IFS
The bench observed that Madhya Pradesh had followed a long-standing practice in which IAS officers—such as district collectors or other senior administrative officials—recorded Annual Confidential Reports (ACRs) for IFS officers, a role that was not in accordance with the top court’s directions.
“It appears that, while other states were adhering to the practice wherein the reporting and reviewing authorities belonged to the same service, the state of Madhya Pradesh was not following this established practice,” the court observed.
“We have no hesitation to hold that the impugned GO is rather contemptuous in nature inasmuch as it is in violation of the orders of this Court dated September 22, 2000, and has been issued without even seeking clarification or modification of this Court,” Chief Justice Gavai wrote in the verdict.
Court Refrains from Contempt, But Orders Compliance Within a Month
Although the court said it could have initiated contempt proceedings against the officials responsible for issuing the GO, it chose not to pursue that route.
“The said GO being in violation of the directions of this court is liable to be quashed and set aside,” the bench stated while directing the Madhya Pradesh government to reframe its rules within one month in line with the 2000 judgment.
Clarifications and Exceptions
The court clarified that while IAS officers such as district collectors may comment on IFS officers’ work in areas like district-level developmental projects, those observations must be routed through a superior IFS officer for appraisal purposes.
It also noted that a 2004 clarification by the Department of Personnel and Training had maintained that the 2000 Supreme Court ruling applied only to IFS officers posted within the forest department, and not those posted on deputation elsewhere.
One-State Exception
The bench highlighted that all other Indian states had been scrupulously following the Supreme Court’s 2000 ruling, and Madhya Pradesh stood out as a lone exception.
The ruling is expected to bring clarity and reinforce service-based autonomy in the appraisal process, particularly in inter-cadre working relationships between the IAS and IFS.
