Acquittal in Criminal Case Does Not Automatically Affect Departmental Proceedings: Punjab & Haryana High Court

The Punjab and Haryana High Court ruled that an acquittal in a criminal case does not automatically impact the outcome of disciplinary proceedings. This is due to the differing standards of proof required in criminal and departmental proceedings.

The petitioners, Harbhajan Singh and another, employed as 'Sewadar' and 'S/Granthi' respectively, were implicated in a case involving an incident at a Gurdwara where another employee vomited near the holy book. Despite not being directly responsible, they were suspended and later penalized by the Shiromani Gurdwara Prabandhak Committee (SGPC). Subsequently, an FIR was filed against them, but they were acquitted by the criminal court. Post-acquittal, they sought the quashing of the departmental charge-sheet and penalties, and requested reinstatement with all benefits.

Whether acquittal by a criminal court affects ongoing or concluded departmental proceedings.

Whether the penalties imposed by the SGPC should be set aside following the criminal acquittal.

Standard of Proof: The court emphasized the differing standards of proof in criminal and departmental proceedings. "The standard of proof in a criminal case is beyond reasonable doubt, whereas in departmental proceedings, it is based on the preponderance of probabilities" (Para 10).

Independent Proceedings: The court reiterated that departmental and criminal proceedings are independent. Citing Supreme Court precedents, it noted, "Acquittal in a criminal case cannot be a ground for interfering with the disciplinary authority's punishment" (Para 9).

Supreme Court Judgments: The court referred to the judgments in Deputy Inspector General of Police v. S. Samuthiram and State of Rajasthan v. Phool Singh to underscore that departmental proceedings can continue independently of criminal trial outcomes (Paras 8-9).

Nature of Acquittal: It was noted that the acquittal of the petitioners was not honorable but due to the prosecution's failure to prove guilt beyond reasonable doubt. This distinction is crucial in determining the impact on departmental actions (Para 10).

Decision: The court dismissed the petition, holding that the disciplinary proceedings and the penalties imposed were valid despite the criminal acquittal. The court found no grounds to interfere under Articles 226/227 of the Constitution, affirming that the penalties were supported by substantial evidence and within the legal framework (Paras 12-13).

Date of Decision: May 14, 2024

Harbhajan Singh and another v. Shiromani Gurdwara Prabandhak Committee and another