Dr. Ram Lakhan Singh v. State Government of Uttar Pradesh
Background
Dr. Ram Lakhan Singh, a retired Indian Forest Service officer who argued his own case, said he was targeted after refusing a request to help denotify a bird sanctuary. He alleged that a vigilance inquiry was started without the mandatory approval of the State Vigilance Committee, that FIRs were registered against him after a High Court order, and that he was arrested, suspended and jailed for about 11 days. The High Court later held that the inquiry had never been properly referred to the Committee, and the State did not dispute this. He asked the Supreme Court for compensation.
Decision Breakdown
The Court found that the State's defence, which alleged disproportionate assets, illegal mining and loss of revenue, was not supported by any material, and that the State's own counsel had not disputed the High Court's findings. The Court said that corruption must be punished, but that honest officers must be protected from malicious and baseless prosecution. Although the Court normally does not award compensation under Article 32, it did so here because of the 11 days in jail, the ten-year legal battle, and the absence of any proven corruption charge. It directed the State of Uttar Pradesh to pay Rs. 10 lakh within three months, and the writ petition was disposed of.
Lesson Learnt
Authorities must follow the prescribed procedure before proceeding against a public servant, and a person wrongly targeted can seek compensation. If the State offers no evidence to justify its actions, the courts may order payment even in a writ petition.