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Supreme Court of India 2018-08-21 partly_allowed

State of Tamil Nadu rep. by Secretary to Govt. (Home) vs Promod Kumar IPS & Anr

Bench: 2 — L. Nageswara Rao

In Brief

The respondent, an IPS officer, was arrested on serious criminal charges (extortion, abuse of power) and placed under suspension under All India Service (Discipline and Appeal) Rules, 1969. A charge memo was issued without the formal approval of the disciplinary authority (Chief Minister). The respondent challenged both the suspension and charge memo. The Tribunal revoked the suspension citing prolonged detention, but upheld the charge memo. The High Court quashed both. The Supreme Court held that the charge memo must be approved by the disciplinary authority at the stage of issuance (not just at initiation), following its earlier B.V. Gopinath judgment. On suspension, the Court found that after six-plus years, continued suspension without concrete evidence of witness tampering was unjustified. The Court upheld the High Court's orders with liberty for the State to reissue the charge memo with proper approval, and allowed reinstatement in a non-sensitive post.

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Administrative Law Civil Service Discipline Suspension Charge Memo Procedural Compliance All India Services Judicial Review

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