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Supreme Court of India 2025-04-23 allowed

DURGA PRASAD vs GOVT. OF NCT OF DELHI & ORS

Bench: 2 — Pamidighantam Sri Narasimha, Manoj Misra

In Brief

A police officer (Durga Prasad), posted as Station House Officer during the 1984 anti-Sikh riots, was charge-sheeted eight years later for alleged dereliction of duty. An inquiry officer exonerated him. The disciplinary authority issued a disagreement note that appeared to pre-judge guilt, and imposed a reduction in rank penalty. The Delhi High Court quashed the punishment but allowed a fresh disciplinary process. The Supreme Court held that given over 40 years had passed, the officer had retired, and the inquiry officer's detailed findings showed he had acted within his available resources, remanding the matter would be unjustly harsh. The Court allowed the appeal and affirmed the quashing of the punishment without permitting fresh proceedings, granting the officer full consequential benefits including pension revision.

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Disciplinary Law Service Law Police Administration Natural Justice 1984 Anti-Sikh Riots CCS (Pension) Rules 1972 Procedural Fairness

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