Citation : 2026 Latest Caselaw 1125 MP
Judgement Date : 4 February, 2026
NEUTRAL CITATION NO. 2026:MPHC-GWL:4447
1 WP-4161-2026
IN THE HIGH COURT OF MADHYA PRADESH
AT GWALIOR
BEFORE
HON'BLE SHRI JUSTICE ASHISH SHROTI
ON THE 4th OF FEBRUARY, 2026
WRIT PETITION No. 4161 of 2026
KU.JYOTI CHATURVEDI
Versus
THE STATE OF MADHYA PRADESH AND OTHERS
Appearance:
Shri Dharmendra Singh Raghuwanshi - Advocate for the
petitioner.
Shri Dharmendra Nayak - Govt. Advocate for the
respondents/State.
ORDER
The petitioner is aggrieved by order dated 23.1.2026, whereby a minor punishment of stoppage of two increments without cumulative effect has been imposed upon the petitioner.
2 . The facts necessary for decision of this case are that the
petitioner is working as In-Charge Project Officer, Project Vijapur-1, in the Women and Child Development Department at Sheopur. A show- cause notice was issued to the petitioner on 18.12.2025, Annexure P/2 to which the petitioner gave detailed reply on 22.12.2025, Annexure P/3. Thereafter, the impugned order has been passed on 23.1.2026, whereby the aforesaid punishment has been imposed.
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3. Learned counsel for the petitioner submitted that the petitioner has given detailed explanation to the allegations made in the show-cause notice. However, the same has not been considered by the authorities.
4 . Learned Government Advocate, on advance notice, tried to justify the impugned order of punishment by referring to the explanation given by the petitioner in her reply.
5. Considered the arguments and perused the record. 6 . The only ground raised by the petitioner in this petition challenging the impugned order is non-consideration of her reply dated 22.12.2025. A perusal of the impugned order dated 23.1.2026, it is evident that except by stating that the petitioner's reply is not found
satisfactory, no reasons have been assigned. The Apex Court has considered the necessity of assigning reasons while passing administrative as also quashi judicial orders in the case of Kranti Associates (P) Ltd. vs. Masood Ahmed Khan reported in (2010)9 SCC
496. The Court summarised the legal position as under:-
"47. Summarising the above discussion, this Court holds:
(a) In India the judicial trend has always been to record reasons, even in administrative decisions, if such decisions affect anyone prejudicially.
(b) A quasi-judicial authority must record reasons in support of its conclusions.
(c) Insistence on recording of reasons is meant to serve the wider principle of justice that justice must not only be done it must also appear to be done as
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(d) Recording of reasons also operates as a valid restraint on any possible arbitrary exercise of judicial and quasi-judicial or even administrative power.
(e) Reasons reassure that discretion has been exercised by the decision-maker on relevant grounds and by disregarding extraneous considerations.
(f) Reasons have virtually become as indispensable a component of a decision-making process as observing principles of natural justice by judicial, quasi-judicial and even by administrative bodies.
(g) Reasons facilitate the process of judicial review by superior courts.
(h) The ongoing judicial trend in all countries committed to rule of law and constitutional governance is in favour of reasoned decisions based on relevant facts. This is virtually the lifeblood of judicial decision-making justifying the principle that reason is the soul of justice.
(i) Judicial or even quasi-judicial opinions these days can be as different as the judges and authorities who deliver them. All these decisions serve one common purpose which is to demonstrate by reason that the relevant factors have been objectively considered. This is important for sustaining the litigants' faith in the justice delivery system.
(j) Insistence on reason is a requirement for both judicial accountability and transparency.
(k) If a judge or a quasi-judicial authority is not
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(l) Reasons in support of decisions must be cogent, clear and succinct. A pretence of reasons or "rubber-stamp reasons" is not to be equated with a valid decision-making process.
(m) It cannot be doubted that transparency is the sine qua non of restraint on abuse of judicial powers. Transparency in decision-making not only makes the judges and decision-makers less prone to errors but also makes them subject to broader scrutiny. (See David Shapiro in Defence of Judicial Candor [(1987) 100 Harvard Law Review 731-37].)
(n) Since the requirement to record reasons emanates from the broad doctrine of fairness in decision-making, the said requirement is now virtually a component of human rights and was considered part of Strasbourg Jurisprudence. See Ruiz Torija v. Spain [(1994) 19 EHRR 553] EHRR, at 562 para 29 and Anya v. University of Oxford [2001 EWCA Civ 405 (CA)] , wherein the Court referred to Article 6 of the European Convention of Human Rights which requires, "adequate and intelligent reasons must be given for judicial decisions".
(o) In all common law jurisdictions judgments play a vital role in setting up precedents for the future. Therefore, for development of law, requirement of giving reasons for the decision is of the essence and is virtually a part of "due process"."
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5 WP-4161-2026 Similar view is reiterated in the case of Oryx Fisheries Private Limited (supra).
7 . Considering the aforesaid, this Court is of the considered opinion that the impugned order of punishment is liable to be set aside on this short ground for want of reasons for not accepting the explanation of the petitioner.
8. Accordingly, the order dated 23.1.2026 is set aside. The matter is remitted to respondent No.2 for reconsideration and passing of a speaking order by assigning reasons for not accepting the explanation of the petitioner.
9. Let a fresh order be passed within a period of 60 days from the date of communication of certified copy of this order.
(ASHISH SHROTI) JUDGE
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