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Supreme Court of India 2023-09-05 dismissed

UNION OF INDIA & OTHERS vs JOGESHWAR SWAIN

Bench: 2 — J. B. Pardiwala, Manoj Misra

In Brief

A Border Security Force constable was dismissed after pleading guilty to photographing a lady doctor without consent. However, the Supreme Court upheld the High Court's decision to set aside his dismissal, finding that the guilty plea was recorded without proper compliance with Rule 142(2) of the BSF Rules, 1969. The court had not explained the consequences of the plea or advised the accused to withdraw it despite weak evidence. Critically, the plea was never signed by the accused, who denied making any confession. With inconsistent witness statements, no proof the camera belonged to him, and the absence of compelling evidence, the Court ruled the dismissal based solely on the plea was unjustified. Procedural safeguards in disciplinary proceedings must be strictly followed, not merely stated verbatim.

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Military Law Administrative Law Evidence Law Natural Justice Procedural Safeguards Confessions Disciplinary Proceedings

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