The Madhya Pradesh High Court has refused to quash disciplinary proceedings against a civil judge, after allegations surfaced claiming that he prepared an acquittal judgment for the accused back in October 2020, even though the trial was pending. [2026 LiveLaw (MP) 255]

The judge allegedly prepared the judgment in furtherance of a conspiracy to confer undue advantage upon the accused Santosh Verma, whose IAS award was held up due to the pendency of a criminal case.

The division bench of Justice Anand Pathak and Justice BP Sharma held that the disciplinary authority is under an obligation to ascertain the allegations and assess whether the conduct of the judicial officer conforms to the expected standards of "integrity and propriety".

Thus, the bench directed:

"The correctness of allegations, sufficiency of evidence and defence of the delinquent employee are matters falling within the domain of the disciplinary authority and not for adjudication in proceedings under Article 226 of the Constitution at the threshold stage. Accordingly, the writ petition being devoid of merit is hereby dismissed. The disciplinary authority shall be at liberty to proceed with the departmental inquiry in accordance with law".

The petitioner-judge had sought quashing of the departmental proceedings on the ground that it would prejudice the ongoing criminal prosecution against him.

Briefly put, the High Court in Criminal Trial 1621 of 2019, noticed allegations that the acquittal of the accused was prepared and brought into existence despite the pendency of the trial. In this backdrop, a disciplinary authority examined the relevant material and initiated proceedings against the petitioner. He was suspended, and a chargesheet was filed against him under Rule 14 of the Madhya Pradesh Civil Services (Classification, Control and Appeal) Rules, 1966.

The counsel for the petitioner argued that the impugned chargesheet deserved to be quashed as it was filed after a gross and unexplained delay. The counsel argued that the alleged incident occurred in 2020 and the chargesheet was only issued in 2025. It was also argued that the criminal case and the departmental proceedings were founded on the same set of facts, and therefore, continuation of departmental proceedings would prejudice the petitioner in the criminal trial.

The counsel for the State, opposing the petition, argued that the allegations against the petitioner are of a grave nature involving the integrity of a judicial officer. The counsel argued that a thorough inquiry was required since such allegations 'strike at the very root of public confidence in the administration of justice'.

The court noted that any interference by a writ court at such a preliminary stage is permissible only in exceptional cases where the authority lacks jurisdiction or action is patently arbitrary. However, the bench also emphasized that the allegations against the petitioner were of the "gravest nature and concern the integrity of the judicial institution itself".

The bench further held, "Matters involving judicial officers necessarily require detailed vigilance scrutiny and careful examination before a decision regarding initiation of disciplinary proceedings is taken".

Therefore, referring to the case of Dinesh Awasthi v State of MP [Writ Petition No.4145 of 2015], the bench held that a delay by itself is not sufficient to invalidate departmental proceedings until it is established that it would cause prejudice to the accused.

The court further rejected the petitioner's objection to the initiation of departmental proceedings with criminal prosecution. The bench further mephasized,

"In the present matter, the allegations concern a member of the judicial service. Public confidence in the judiciary constitutes one of the foundational pillars of the constitutional system. The disciplinary authority is under an obligation to ascertain whether the conduct of a judicial officer conforms to the standards of integrity and propriety expected from the office held by him. Such inquiry cannot be indefinitely postponed awaiting conclusion of criminal proceedings, the duration of which remains uncertain".

Accordingly, the court dismissed the petition and granted liberty to proceed with the departmental inquiry in accordance with the law.

Case Title: V v State of Madhya Pradesh, WP-18568-2026

For Petitioner: Advocate Narendra Chouhan

For State: Government Advocate Kanak Gaharwar

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