In a scathing critique of the Madhya Pradesh government, the Supreme Court on Wednesday struck down a government order that allowed Indian Administrative Service (IAS) officers to review the Annual Confidential Reports (ACRs) of Indian Forest Service (IFS) officers. The court termed the move “contemptuous” and in direct violation of a prior Supreme Court judgment.
Court’s Rebuke and Ruling
A bench led by Chief Justice D.Y. Chandrachud and Justice Augustine George Masih ruled that the state’s Government Order (GO), dated June 29, 2024, blatantly violated the Supreme Court’s landmark ruling from September 22, 2000. That earlier judgment had laid out specific guidelines on performance appraisals for officers of the All India Services.
“We have no hesitation in holding that the impugned GO is clearly contemptuous… It was issued without even seeking a clarification or modification of this Court’s prior directions,” Chief Justice Chandrachud stated in the judgment.
Key Points from the 2000 Supreme Court Ruling
The apex court had made it clear in 2000 that:
For IFS officers up to the rank of Additional Principal Chief Conservator of Forests, performance appraisals must be reviewed only by their immediate superiors within the forest department.
Only in the case of Principal Chief Conservators of Forests — who have no higher-ranking IFS officer above them — can an officer from another service (e.g., IAS) act as the reviewing authority.
Non-Compliance by Madhya Pradesh
The court noted that while all other states had complied with these guidelines, Madhya Pradesh had failed to do so, continuing to permit IAS officers, such as district collectors, to review the ACRs of IFS officers in defiance of the law.
“It appears that Madhya Pradesh has not adhered to this established practice, unlike other states,” the bench remarked.
Although the court observed it had grounds to initiate contempt proceedings, it opted not to pursue them. Instead, it declared the Government Order void:
“We refrain from initiating contempt proceedings. However, the GO, being in violation of this Court’s directions, is hereby quashed and set aside.”
Directions to the Madhya Pradesh Government
The court ordered the Madhya Pradesh government to revise its rules within one month in full compliance with the 2000 ruling. It emphasized that IFS appraisals must remain within the forest service hierarchy. Any feedback from IAS officers, such as district collectors, should be recorded separately and evaluated only by superior forest officials.
The bench also cited a 2004 clarification issued by the Department of Personnel and Training (DoPT), which reaffirmed that the 2000 ruling applies exclusively to IFS officers serving within the forest department—not to those on deputation or posted elsewhere.
Broader Implications
This judgment reinforces the principle of cadre autonomy and underscores the judiciary’s commitment to maintaining the institutional integrity of India’s civil services. It serves as a firm reminder that cross-cadre supervision must remain within clearly defined constitutional and legal boundaries.
