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Supreme Court of India 2025-04-23 allowed

MAHARANA PRATAP SINGH vs THE STATE OF BIHAR & ORS

Bench: 2 — Dipankar Datta, Prashant Kumar Mishra

In Brief

A police constable appointed in 1973 was dismissed in 1996 following disciplinary proceedings based on a criminal complaint involving extortion charges. Though acquitted in criminal proceedings, the departmental inquiry found him guilty. The Supreme Court held that the dismissal violated due process and natural justice. The chargesheet was vague and lacked material particulars; the complainant was not examined; and the officer was denied the right to cross-examine a key witness (PW-1). The Court reiterated that mere suspicion cannot substitute for proof even in domestic inquiries, and when criminal and departmental proceedings involve substantially identical charges and witnesses, acquittal should render disciplinary findings vulnerable. The Court set aside the dismissal, awarded ₹30 lakh compensation, and imposed ₹5 lakh costs on the respondents.

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Service Law Disciplinary Proceedings Natural Justice Administrative Law Police Service Due Process Criminal Procedure Evidence

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