Guwahati: In a significant ruling, the Supreme Court of India on Wednesday struck down a Madhya Pradesh government order that permitted Indian Administrative Service (IAS) officers to review the performance appraisal reports of Indian Forest Service (IFS) officers.
The apex court termed the state’s move “contemptuous” and a direct violation of its long-standing judicial directions.
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A bench comprising Chief Justice of India D.Y. Chandrachud and Justice Augustine George Masih declared the June 29, 2024, government order (GO) to be in “total violation” of the Supreme Court’s previous binding judgment from September 22, 2000.
“We have no hesitation in holding that the impugned GO is rather contemptuous in nature,” the court observed, noting that Madhya Pradesh issued the order without seeking any clarification or modification of the two-decade-old ruling.
“The 2000 Supreme Court judgment explicitly mandated that an immediate superior from within the forest department assess IFS officers up to the rank of Additional Principal Chief Conservator of Forests.”
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Only the Principal Chief Conservator of Forests, the highest post, could have a non-forest officer as a reviewing authority due to the absence of a senior within the service.
The bench highlighted that while other states had complied with this directive, Madhya Pradesh had continued a practice where IAS officers, including district collectors, assessed IFS officers, impacting their Annual Confidential Reports (ACRs), crucial for promotions and career advancement.
“Taking serious note of the violation, the Supreme Court warned that it could have initiated contempt proceedings but refrained, emphasizing that it would quash and set aside the GO.”
The court further ordered the Madhya Pradesh government to frame fresh rules within one month, strictly adhering to the 2000 Supreme Court directions.
The judgment clarified that while IAS officers like collectors might need to record comments on IFS officers regarding district-level development projects, such comments must be on a separate sheet and reviewed by a superior officer within the forest department itself.
The court also acknowledged a September 2004 clarification from the Department of Personnel and Training (DoPT), which reiterated that the 2000 ruling applied specifically to forest officers working within the forest department, not those on deputation or posted outside.
This ruling strongly reasserts the autonomy and internal hierarchy of the Indian Forest Service, marking a firm judicial pushback against bureaucratic overreach by state administrations that conflict with court orders.