Punjab and Haryana High Court Upholds Disciplinary Action Against CISF Constable

Court Dismisses Petition Challenging Enhanced Punishment for Alleged Misconduct During Religious Gathering

The Punjab and Haryana High Court, on October 16, 2025, upheld the disciplinary action taken against Gurnam Singh, a CISF constable, dismissing his plea for quashing the orders related to his alleged misconduct at a religious gathering. The court, presided by Justice Sandeep Moudgil, ruled that the disciplinary proceedings were justified and in accordance with legal principles.

Gurnam Singh was charged with delivering an inflammatory speech at a religious gathering in his native village, which purportedly incited public unrest. Despite the Enquiry Officer's report finding him not guilty, the disciplinary authority imposed a penalty of pay reduction, which was later enhanced to a more severe penalty after a show cause notice.

The court emphasized the limited scope of judicial review in disciplinary matters, stressing that its role is not to act as an appellate body but to ensure the process adhered to principles of natural justice. It found that the disciplinary authority had lawfully disagreed with the Enquiry Officer’s findings, providing detailed reasons for its decision.

The court also noted that the standards of proof in departmental inquiries differ from criminal proceedings, and the absence of a criminal case does not invalidate disciplinary actions. Justice Moudgil further highlighted the heightened responsibility of armed forces personnel to maintain discipline and avoid actions that could undermine public order.

The judgment reaffirmed the right of disciplinary authorities to make independent decisions based on available evidence and reiterated the importance of proportional punishment in maintaining the integrity of the armed forces.

Bottom Line:

Scope of judicial review in disciplinary matters is limited to examining adherence to natural justice, presence of evidence, absence of malafide or arbitrariness, and proportionality of punishment.

Statutory provision(s): Articles 226/227 of the Constitution of India, CISF Act, 1968 Section 15(A).

Gurnam Singh Constable v. Union of India, (Punjab And Haryana) : Law Finder Doc Id # 2799766