The case was presided over by Justice Venkata Jyothirmai Pratapa. Srikanth’s lawyer, K.R. Srinivas, argued that the disciplinary action stemmed from speculative findings by the inquiry officer. The respondents, including senior police officials and the State of Andhra Pradesh, defended the actions taken against Srikanth.
Andhra Pradesh: The Andhra Pradesh High Court quashing the disciplinary penalty imposed on police constable G. Srikanth. The court highlighted that decisions must be based on legally admissible evidence.
Case Background
G. Srikanth, from Ananthapur District, filed Writ Petition No. 15720 of 2019 challenging disciplinary action following accusations of demanding “Matka Mamool” (illegal gambling money) from a civilian, Jelli Peddama, in 2008, while he served at Guntakal I Town Police Station.
He faced suspension, and an internal inquiry led to a penalty of two years’ postponement of increments, adversely affecting his future increments and pension.
The case was presided over by Justice Venkata Jyothirmai Pratapa. Srikanth’s lawyer, K.R. Srinivas, argued that the disciplinary action stemmed from speculative findings by the inquiry officer. The respondents, including senior police officials and the State of Andhra Pradesh, defended the actions taken against Srikanth.
Key Legal Issues
- Adequacy of Evidence: The core issue was whether the evidence from the inquiry justified imposing a significant penalty on Srikanth.
- Adherence to Natural Justice: Srikanth contended that the inquiry officer did not adequately consider his defense, including his medical leave records.
- Legality of the Disciplinary Process: The court assessed if the disciplinary authorities followed established rules, especially concerning reasoning and evidentiary support for their decision.
Contentions and Evidence
- Petitioner’s Arguments:
- Srikanth asserted he was on medical leave for chickenpox during the alleged misconduct, supported by medical records.
- The complainant, Jelli Peddama, denied any money was demanded and claimed his prior statement was made without full understanding.
- Srikanth maintained the inquiry officer’s conclusions were based on assumptions, lacking solid evidence, and criticized the lack of adequate reasoning from the disciplinary authorities.
- Respondents’ Stand:
- The respondents argued that the inquiry followed procedural norms and that the penalty was appropriate for the alleged misconduct.
- They contested the credibility of Srikanth’s medical records regarding his absence during the incident.
- The government pleader suggested remanding the case for reconsideration if the inquiry was deemed flawed.
Key Observations by the Court
Justice Pratapa noted significant deficiencies in the inquiry process:
- Insufficient Evidence:
- The court found the inquiry officer’s findings inconsistent with the evidence, noting that the complainant testified he never paid Srikanth.
- The court stated, “The findings of the Enquiry Officer are contrary to the record,” emphasizing that decisions must rely on legally admissible evidence.
- Violation of Natural Justice:
- While the Evidence Act may not apply strictly in departmental proceedings, the principles of natural justice must be upheld.
- The court criticized the inquiry officer’s reliance on assumptions, declaring that “the order of the Enquiry Officer was based on surmises and conjectures,” making the decision legally unsustainable.
- Lack of Reasoning in Orders:
- The disciplinary and appellate authorities failed to provide adequate reasoning for their orders, which is crucial when imposing significant financial penalties.
- The judgment stressed that decisions with major financial implications must be supported by clear, reasoned findings.
Court’s Final Decision
The High Court ruled that the disciplinary order against Srikanth was legally unfounded and quashed the penalty of postponed increments, deeming it unjustified due to the lack of reliable evidence.
The court concluded that “the imposition of such a major penalty requires strict adherence to procedural fairness and legally admissible evidence,” affirming that inquiries must be based on substantial evidence establishing misconduct beyond reasonable doubt.
