IN RE: PERFORMANCE APPRAISAL REPORTS OF THE OFFICERS OF THE INDIAN FOREST SERVICE versus

IN RE: PERFORMANCE APPRAISAL REPORTS OF THE OFFICERS OF THE INDIAN FOREST SERVICE versus

The impugned Government Order dated 29 June 2024 is quashed as being in violation of this Court's earlier directions; for IFS officers up to the rank of APCCF the reporting and reviewing authorities must be the immediate superiors within the Forest Department (only the PCCF may have a reporting authority outside the service to whom he reports and who is superior in rank); the State of Madhya Pradesh is directed to reframe rules in conformity with Santosh Bharti and the clarifications of MoEF and DoPT within one month.

Parties
Applicant: Gaurav Kumar Bansal; Applicant: Unnamatla Prakasham; Applicant: Indian Forest Service Association (State Unit)
Jurisdiction
India
Judgment Date
21 May 2025
Procedural Posture
Original Jurisdiction Under Article 32 / Judgment
Outcome
Applications allowed
Legal Topics
Performance Appraisal Report, Reporting Authority, Reviewing Authority, Accepting Authority, Indian Forest Service, Annual Confidential Report
Service Law Administrative Law Performance Appraisal Report Reporting Authority Reviewing Authority Accepting Authority Indian Forest Service Annual Confidential Report

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Parties

Gaurav Kumar Bansal

Applicant

Unnamatla Prakasham

Applicant

Indian Forest Service Association (State Unit)

Applicant

Procedural Posture

Original Jurisdiction Under Article 32 / Judgment

Legal Issues

  1. 1 Whether officers of the Indian Administrative Service can be reporting/reviewing/accepting authorities for officers of the Indian Forest Service
  2. 2 Validity of Government of Madhya Pradesh G.O. dated 29.06.2024 prescribing PAR/ACR channels for IFS officers
  3. 3 Interpretation and application of All-India Services (Confidential Rolls) Rules, 1970 (as amended) and All-India Services (Performance Appraisal Report) Rules, 2007, and prior Supreme Court directions

Ratio Decidendi

The impugned Government Order dated 29 June 2024 is quashed as being in violation of this Court's earlier directions; for IFS officers up to the rank of APCCF the reporting and reviewing authorities must be the immediate superiors within the Forest Department (only the PCCF may have a reporting authority outside the service to whom he reports and who is superior in rank); the State of Madhya Pradesh is directed to reframe rules in conformity with Santosh Bharti and the clarifications of MoEF and DoPT within one month.

Court Disposition

Applications allowed

Orders

  • The impugned Government Order dated 29th June 2024 is quashed and set aside.
  • The State of Madhya Pradesh is directed to reframe rules strictly adhering to the directions issued by this Court vide order dated 22nd September 2000 (Santosh Bharti) as clarified by the MoEF letter dated 8th November 2001 and the DoPT O.M. dated 2nd September 2004.