VidhiSangh

Supreme Court of India · 31/03/2025

AMRESH SHRIVASTAVA versus THE STATE OF MADHYA PRADESH & ORS.

[2025] 4 S.C.R. 488 · 2025 INSC 417

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Summary

A Tehsildar was chargesheeted in 2011 for a land settlement order he had passed in 1997 in exercise of quasi-judicial powers, the charge being that the settlement was illegal and indicative of dishonesty. The Supreme Court held that the charge amounted to no more than an allegation of a wrong order, with no material of extraneous influence or gratification, and so fell outside the categories in K.K. Dhawan that permit disciplinary action for quasi-judicial orders; it further held that unexplained inordinate delay in initiating proceedings, where the department knew of the alleged misconduct, itself justified quashing the chargesheet.

Issues

  1. Whether the chargesheet against a revenue officer for a quasi-judicial land settlement order falls within the situations identified in Union of India v. K.K. Dhawan in which disciplinary action may be taken for the exercise of quasi-judicial powers.
  2. Whether inordinate and unexplained delay in issuing a chargesheet is by itself a ground to quash it.

Provisions considered

Held

Result

Appeal allowed; the Division Bench judgment dated 30.04.2019 set aside and the Single Judge's order dated 26.04.2017 quashing the chargesheet dated 29.04.2011 restored. No order as to costs; pending applications disposed of.

Judgment PDF: Supreme Court of India, [2025] 4 S.C.R. 488.