21 May 2025 Administrative Law >> Constitution & Law Procedure  

In a significant ruling, the Supreme Court of India on May 21, 2025, in the case titled In Re: Performance Appraisal Reports of The Officers of The Indian Forest Service, quashed a Madhya Pradesh Government Order (G.O.) dated June 29, 2004. The Court found the G.O. to be in direct violation of its previous directions concerning the performance appraisal reports of Indian Forest Service (IFS) officers, thereby reaffirming its stance on adherence to judicial pronouncements in framing service rules.

Background of the Dispute:

The case involved multiple interlocutory applications within an ongoing writ petition dating back to 1995. The core issue revolved around the validity and impact of a specific G.O. issued by the State of Madhya Pradesh on June 29, 2004. This G.O. pertained to the performance appraisal reports of IFS officers and was challenged for allegedly contravening previous orders of the Supreme Court.

Crucially, the impugned G.O. was deemed to be in violation of the Supreme Court's order dated September 22, 2000, in the Santosh Bharti case, which was part of the same ongoing proceedings. This 2000 order had laid down specific guidelines or clarifications, which were further explained by the Ministry of Environment and Forests (MoEF) in a letter dated November 8, 2001, and by the Department of Personnel and Training (DoPT) on September 2, 2004. The applicants argued that the 2004 G.O. contradicted these foundational directives.

Court's Analysis and Decision:

The Supreme Court, presided over by the Honourable Chief Justice Mr. B.R. Gavai and Mr. Justice Augustine George Masih, meticulously examined the statutory provisions, internal communications, and relevant legal precedents. The Court observed that the G.O. dated June 29, 2004, indeed disregarded the clear directions previously issued in the Santosh Bharti case and the subsequent clarifications from MoEF and DoPT.

The bench unequivocally stated that the impugned G.O., being contrary to the Court's earlier orders, was liable to be quashed and set aside. While the Court expressed that it could initiate proceedings against the officers responsible for issuing such a defiant G.O., it chose to refrain from doing so, focusing instead on rectifying the legal anomaly.

Directives Issued by the Supreme Court:

In its final order, the Supreme Court allowed the applications and issued the following directives:

1. The present applications are allowed.
2. The impugned G.O. dated June 29, 2004, is declared to be in violation of the Supreme Court's order dated September 22, 2000 (Santosh Bharti case), which was reiterated, and is therefore quashed and set aside.
3. The State of Madhya Pradesh is directed to reframe the rules pertaining to performance appraisal reports by strictly adhering to the directions issued by the Supreme Court on September 22, 2000, as clarified by the MoEF on November 8, 2001, and by the DoPT on September 2, 2004.
4. This reframing of rules must be completed within a period of one month from the date of the judgment.

The Court also placed on record its appreciation for the efforts of Shri K. Parashar.

Conclusion:

This judgment serves as a strong reminder to government authorities regarding the imperative to comply with judicial directives when formulating administrative rules and policies. By quashing the non-compliant G.O. and setting a strict timeline for reframing the rules, the Supreme Court has underscored its commitment to upholding the sanctity of its orders and ensuring proper governance in public service.