Can an officer be charge sheeted in respect of the action performed by him in his quasi-judicial capacity?
19. Can an officer be charge sheeted in respect of the action performed by him in his quasi-judicial capacity? One of the issues for determination before the Central Administrative Tribunal (Principal Bench) in Ashish Abrol, Joint Commissioner of Income Tax Vs. Union of India (UOI) through The Secretary, Ministry of Finance, Department of Revenue and Director General of Income Tax (Vigilance) [MANU/CA/0171/2010] was as under: (ii) Whether action could have been initiated against the Applicant while passing an order of assessment in quasi-judicial proceedings? In its decision dated 23.4.2010, the Principal Bench referred to a number of decisions of the Hon’ble Supreme Court and the High Court of Delhi including that of Union of India and Ors v. K.K. Dhawan MANU/SC/0232/1993: 1993 (2) SCC 56, wherein the Supreme Court held that when an officer in exercise of judicial or quasijudicial powers acts negligently or recklessly or in order to confer undue favour on a person, he is not acting as a Judge. There is a great reason and justice for holding in such cases that the disciplinary action could be taken. It is one of the cardinal principles of administration of justice that it must be free from bias of any kind. The above judgment also provides the non-exhaustive list of the circumstances wherein disciplinary action can be taken against the erring official: Where the officer had acted in a manner as would reflect on his reputation for integrity or good faith or devotion of duty; If there is prima facie material to show recklessness or misconduct in the discharge of his duty; If he has acted in a manner which is unbecoming of a Government servant; If he had acted negligently or that he omitted the prescribed conditions which are essential for the exercise of the statutory powers; If he had acted in order to unduly favour a party; If he had been actuated by corrupt motive, however small the bribe may be.