The Madhya Pradesh High Court has delivered a sharp rebuke to government departments for their "lethargic attitude" and "inaction" that cause inordinate delays in disciplinary proceedings against errant officials. The court's Gwalior bench, led by Justice Ashish Shroti, made these observations while denying relief to an assistant veterinary field officer accused of fraudulently claiming medical reimbursements using forged documents.
Court Upholds Chargesheets, Cites Serious Allegations
Justice Ashish Shroti was hearing a writ petition filed by the official from the Animal Husbandry and Dairying Department. The petitioner sought to quash two departmental chargesheets issued against him in 2019 and 2024 and to restrain authorities from proceeding with disciplinary action.
The chargesheets accused the officer of defrauding the government of approximately Rs 9.64 lakh by submitting forged and fabricated medical bills for himself and his wife to claim reimbursements for the periods 2010-2011 and 2014-2015.
In its order dated December 24, 2025, the court dismissed the petition, allowing the authorities to proceed with the 2024 chargesheet. The bench directed that the disciplinary proceedings be concluded expeditiously and without further delay.
"Public Money at Stake": Court's Stern Warning
The court's order minced no words in criticising the systemic delays plaguing government departments. It noted that such delays often occur due to the "lethargic attitude and inaction on the part of responsible officers" or due to "the influence that may have been exercised by the delinquent" employee.
"Nobody personally loses anything because of such a delay. However, ultimately, it is the public money and/or public interest that is to be taken into account," the order stated.
Justice Shroti clarified that while delay might be a valid ground for quashing charges in cases involving trivial allegations, this principle cannot apply where allegations are "serious in nature." The court emphasised that the present case involved not just public money but also the "integrity and honesty" of the employee, which needed thorough examination.
"In the facts and circumstances of this case, it would not be in the interest of clean and honest administration that the charge-sheet is quashed at this stage merely on the ground of delay," the order read.
Petitioner's Arguments on Delay and Double Jeopardy Rejected
The petitioner's counsel, advocate D P Singh, had argued for quashing the chargesheets on grounds of "inordinate unexplained" delay. He pointed out that the alleged incidents occurred in 2010-2011 and 2014-2015, but the chargesheets were issued only in 2019 and 2024 with no explanation for the gap.
Singh also contended that issuing a show-cause notice followed by subsequent chargesheets for the same allegations amounted to double jeopardy, which is prohibited under Article 20(2) of the Constitution of India.
The court, however, found these arguments lacking merit. On the double jeopardy claim, the bench held that Article 20(2) prohibits multiple prosecution or punishment for the same offence. Since no punishment had been imposed on the petitioner and no enquiry had commenced based on the earlier notices, the doctrine did not apply.
Government counsel K S Tomar successfully argued that there was no inaction by the authorities, as show-cause notices and chargesheets were issued periodically. He stressed that chargesheets involving serious allegations of fraud could not be quashed solely on the ground of delay in issuance.
The court concurred, noting the allegations were backed by documentary evidence and involved a significant sum of public money. The ruling underscores the judiciary's growing impatience with procedural delays that compromise accountability in public service.
