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The State of Madhya Pradesh & Ors. v. Bunty

Civil Appeal · 2019 INSC 368Decided 14 Mar 2019
Civil Appeal No. 3046 of 2019
Justice Arun Mishra · Justice Navin Sinha

Background

The respondent, Bunty, cleared the selection process for the post of Police Constable in Madhya Pradesh in 2013-14, but was denied appointment after a Screening Committee found he had been involved in a criminal case (under IPC Sections 392 and 411, involving impersonation as a police officer) during the selection process, in which he was acquitted only on benefit of the doubt rather than a clean/honourable acquittal. A single judge of the Madhya Pradesh High Court upheld the denial of appointment, but a Division Bench reversed this, holding the acquittal entitled him to appointment as a matter of course, leading the State to appeal to the Supreme Court.

Decision Breakdown

The Supreme Court held that an acquittal based merely on benefit of the doubt (because witnesses turned hostile), rather than a clean exoneration on merits, does not automatically entitle a candidate to appointment, especially for a disciplined force like the police where character and integrity are paramount. Relying on its earlier decisions in Mehar Singh, Avtar Singh, and Pradeep Kumar, the Court held that the Screening Committee's considered, non-arbitrary decision on a candidate's fitness is not ordinarily open to judicial interference, and that the nature of the offence here (involving moral turpitude) justified treating the candidate as unsuitable. The Court set aside the Division Bench's judgment, restored the single judge's order upholding the denial of appointment, and allowed the State's appeal with no order as to costs.

Lesson Learnt

Being acquitted of a criminal charge does not automatically guarantee a government job, especially in disciplined services like the police: if the acquittal was only a "benefit of the doubt" rather than a clean exoneration, the employer's screening committee can still lawfully treat the candidate as unfit based on the nature of the underlying allegation.

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

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