Quasi-Judicial Decisions of Revenue Officers Cannot Invite Disciplinary Action for Mere Errors: MP High Court

In Virendra Kumar Katare v. General Administration Department & Ors., the Madhya Pradesh High Court quashed a charge sheet issued against a Deputy Collector, holding that actions taken while performing quasi-judicial duties under the Madhya Pradesh Land Revenue Code, 1959, are protected under the Judges (Protection) Act, 1985.

Justice Jai Kumar Pillai was hearing a writ petition filed by Virendra Kumar Katare, who challenged disciplinary proceedings initiated against him for orders passed in 2013 during his tenure as Tehsildar, Ratlam. The allegations related to auction proceedings of attached land and mutation of property based on a Will.

The State claimed that the petitioner had acted irregularly by conducting auction proceedings and allowing mutation of Bhu-daan land without proper verification and statutory permission. However, the Court observed that mutation proceedings, appreciation of a Will, and evaluation of inquiry reports are adjudicatory functions performed by Revenue Courts.

Relying on Union of India v. K.K. Dhawan and Amresh Shrivastava v. State of M.P., the Court reiterated that disciplinary action against officers exercising quasi-judicial powers can arise only where there are allegations of mala fide intent, corruption, recklessness, or undue favour. No such allegations were present in the case.

The Court also noted the unexplained six-year delay in issuing the charge sheet and found the allegations vague and unsupported by specific particulars. Consequently, the High Court quashed the charge sheet and directed authorities to reconsider the petitioner’s promotion to the post of Joint Collector without being influenced by the disciplinary proceedings.