Clean chit in disciplinary proceedings can't lead to quashing of criminal case, says Supreme Court

New Delhi: The Supreme Court has said in a disciplinary proceeding, the proof is of preponderance of probabilities while in a criminal proceeding, it has to be the higher standard of proof beyond reasonable doubt, but the exoneration in the former can't result in quashing the latter case.

A bench of Justices Ahsanuddin Amanullah and K Vinod Chandran rejected a contention that when the allegations could not be proved in a disciplinary proceeding where the requirement is only of preponderance of probabilities, surely it cannot be proved beyond reasonable doubt.

The court emphasised that the disciplinary proceedings and the criminal prosecution of an employee in a bribery case are independent of each other, the decision in one case cannot govern the outcome in the other.

"Despite this court having consistently held that disciplinary proceedings and criminal prosecution, even on an identical allegation, are parallel proceedings, the relevance of the conclusion in one is often contended to be binding on the other,'' the bench said.

The bench allowed an appeal filed by the Karnataka Lokayuktha Bagalkote against the Karnataka High Court's order.

On a writ petition filed by Chandrashekar, an executive engineer with the Works and Maintenance Division, HESCOM, Bagalkot, the High Court quashed his criminal prosecution in a corruption case for allegedly demanding and accepting bribe from a contractor to clear five bills, at the rate of Rs 2,000 each, as the departmental proceedings ended in his exoneration.

The bench, however, said, both (disciplinary and criminal proceedings) are independent of each other not only for the reason of the nature of the proceedings and the standard of proof, but also for the reason of the adjudication being carried on by two different entities, regulated by a different set of rules and more importantly decided on the basis of the evidence led in the independent proceedings.

"If evidence is not led properly in one case, it cannot govern the decision in the other case where evidence is led separately and independently,'' the bench said in a judgment on January 6, 2026.

After looking at the evidence laid at the enquiry in the departmental proceedings in the case at hand, the court found the total exoneration on merits was absent.

"We are not convinced that this was a fit case where the criminal proceedings can be quashed on the exoneration of the delinquent employee in a departmental enquiry,'' the bench said.

The court, however, clarified, since the disciplinary authority has accepted the enquiry report, there cannot be reopening of it, but a conviction in the criminal case would bring in consequences as mandated by rules regulating the service.