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Sadhna Chaudhary v. The State of Uttar Pradesh

Civil Appeal · 2020 INSC 292Decided 6 Mar 2020
Civil Appeal No. 2077 of 2020
Chief Justice S.A. Bobde · Justice B.R. Gavai · Justice Surya Kant

Background

Sadhna Chaudhary, a member of the Uttar Pradesh Higher Judicial Service, was dismissed from service after a disciplinary enquiry found that two land-acquisition compensation orders she passed as an Additional District Judge awarded unusually large, "shockingly" high amounts, which an enquiry committee treated as evidence she had been swayed by extraneous considerations. Her writ petition challenging the dismissal was rejected by the Allahabad High Court, which held the decision-making process (not the correctness of the outcome) could be examined in a disciplinary enquiry.

Decision Breakdown

The Supreme Court agreed with the general legal principle that a judge's conduct, not the correctness of their decision, is what matters for misconduct, but found that in this case, the chargesheet never alleged any specific bribe, extraneous factor, or improper conduct in her decision-making process; it inferred dishonesty purely from the size of the award. Crucially, one of her two orders had since been further enhanced and effectively endorsed by the Supreme Court itself in unrelated proceedings, undermining the claim that the outcome was aberrant. Finding the entire basis for the charge had collapsed, the Court set aside her dismissal, quashed the disciplinary order, and directed her reinstatement with consequential and retiral benefits.

Lesson Learnt

A judge or judicial officer cannot be dismissed for misconduct simply because a decision produced a generous or unusual outcome: there must be actual evidence that the decision-making process itself was dishonest or influenced by something improper, not just hindsight disagreement with the result.

Official source (sci.gov.in)View Judgment (PDF)

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