IN RE: PERFORMANCE APPRAISAL REPORTS OF THE OFFICERS OF THE INDIAN FOREST SERVICE versus
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[2025] 5 S.C.R. 1449 : 2025 INSC 748 In Re: Performance Appraisal Reports of the Officers of the Indian Forest Service [(I.A. No. 172422 of 2024 with I.A. No(s). 172425, 172427, 172429, 179359, 290215, 290217 of 2024 and I.A. No(s). 105862, 105864 and 105865 of 2025) In (Writ Petition (C) No. 202 of 1995)] In Re: T.N. Godavarman Thirumulpad v. Union of India and Others In the Matter of: Gaurav Kumar Bansal ... Applicant Unnamatla Prakasham ... Applicant Indian Forest Service Association (State Unit) ... Applicant 21 May 2025 [B.R. Gavai, CJI* and Augustine George Masih, J.] Issue for Consideration Issue arose as to whether the officers in the Indian Administrative Service-IAS would be a “reporting authority”, “reviewing authority” and “accepting authority” of the officers working in the Indian Forest Service-IFS. Headnotes† Service law – Performance Appraisal Report – Writing Performance Appraisal Report of the officers belonging to the Indian Forest Service-IFS by the officers in the Indian Administrative Service-IAS – Propriety: Held: For writing Annual Confidential Reports-ACRs, in relation to officers up to the rank of Additional Principal Chief Conservator of Forest-APCCF, the “reviewing authority” or “reporting authority” should be the immediate superior authority-PCCF in the Forest Department – Thus, up to the APCCF, the “reporting authority” and the “reviewing authority” would be the person within the same department – It is only with regard to Principal Chief Conservator of Forests-PCCF that the “reporting authority” would be a person * Author 1450 [2025] 5 S.C.R. Supreme Court Reports who was familiar with the work of PCCF and would be a person to whom he reports and who is superior to him in rank and hierarchy – Said “reporting authority” would be a person other than the one belonging to the service because there was no one superior to the PCCF within the service – Government Order dated 29.06.2024 notified by the Government of Madhya Pradesh with regard to writing Performance Appraisal Report of the officers belonging to the IFS that before evaluating the performance of the Divisional Forest Officer (Territorial), Conservator or Chief Conservator of Forest (Reporting Authorities) will seek a note from the District Collector and before evaluating the performance of the Conservator of Forests and Chief Forest Conservator (Territorial), Additional Principal Chief Forest Conservator (Development) will seek a note from the Divisional Commissioner – Said G.O. in violation of the order passed by this Court in the present proceedings dated 22.09.2000 –**Santosh Bharti’s case and is quashed and set aside – State of Madhya Pradesh to reframe the rules by strictly adhering to the directions issued in – **Santosh Bharti’s case, and as clarified by the MoEF and DoPT. [Paras 34, 37, 39, 41] Case Law Cited **Santosh Bharti v. State of Madhya Pradesh (2007) 15 SCC 273 – relied on. State of Haryana v. P.C. Wadhwa, IPS Inspector General of Police and Another [1987] 2 SCR 1030 : (1987) 2 SCC 602; State of Assam and Others v. Binod Kumar and Others [2024] 1 SCR 473 : (2024) 3 SCC 611 – referred to. List of Acts Constitution of India; Madhya Pradesh Government Business (Allocation) Rules; All-India Services Act, 1951; All-India Services (Confidential Rolls) Rules, 1970; All India Services (Confidential Rolls) Second Amendment Rules, 1970; All-India Services (Performance Appraisal Report) Rules, 2007. List of Keywords Indian Administrative Service; “Reporting authority”; “Reviewing authority”; “Accepting authority”; Indian Forest Service; Performance Appraisal Report; Writing Performance Appraisal Report of the officers belonging to Indian Forest Service by the officers in the Indian Administrative Service; Annual Confidential Reports; [2025] 5 S.C.R. 1451 In Re: Performance Appraisal Reports of the Officers of the Indian Forest Service Additional Principal Chief Conservator of Forest; Immediate superior authority; Forest Department; Principal Chief Conservator of Forests; Superior in rank and hierarchy; Government Order dated 29.06.2024; Divisional Forest Officer (Territorial); Conservator or Chief Conservator of Forest (Reporting Authorities); District Collector; Conservator of Forests and Chief Forest Conservator (Territorial); Divisional Commissioner; **Santosh Bharti’s case. Case Arising From INHERENT/ORIGINAL JURISDICTION: Under Article 32 of The Const
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