Misconduct

Misconduct, for a central government servant, is conduct that breaches the duties laid down in the Central Civil Services (Conduct) Rules, 1964, or is otherwise blameworthy in the context of those rules, and that can be punished under the CCS (Classification, Control and Appeal) Rules, 1965. Neither set of rules defines the word. Its meaning comes from the Supreme Court, which held in State of Punjab v. Ram Singh (1992) 4 SCC 54 that misconduct is a transgression of an established rule of action or code of conduct, and not a mere error of judgment, carelessness or negligence in the performance of duty.

The CCA Rules speak only of “imputations of misconduct or misbehaviour” in Rule 14 and allow a penalty under Rule 11 “for good and sufficient reasons”. The Conduct Rules state general duties in Rule 3, such as absolute integrity, devotion to duty and doing nothing unbecoming of a government servant, and then list specific prohibitions from Rule 3-A to Rule 22-A. A charge can rest on a specific prohibition, on a general duty, or on conduct the rules never mention, and the Supreme Court held in Union of India v. J. Ahmed (7 March 1979) that the code is not exhaustive.

What a reader in service needs is the boundary. On one side sit inefficiency, a wrong order and a single honest mistake, which are not misconduct. On the other sit gross or habitual negligence, a mistake with serious consequences, and the six situations the Supreme Court set out in Union of India v. K.K. Dhawan (1993) 2 SCC 56 for officers exercising quasi-judicial powers. Private life falls inside the boundary where a Conduct Rule reaches it directly, as the rules on dowry, indebtedness and bigamous marriage do, or where the act has a reasonable connection with the service or reflects on the servant’s integrity.

A proved charge of misconduct can end in any of the ten penalties in Rule 11, from censure to dismissal from service, and dismissal or removal forfeits pension and gratuity under Rule 41 of the CCS (Pension) Rules, 2021, subject to a compassionate allowance of up to two-thirds of the pension or gratuity or both, which the authority may sanction in a case deserving special consideration. A finding of grave misconduct or negligence during service can reach a pension already in payment under Rule 8 of the same rules. This article covers the sources of the duty, the Supreme Court tests, the negligence line, quasi-judicial acts, private conduct, how misconduct is drafted into an article of charge, the standard of proof, the choice of penalty, the pension consequence, and the parallel All India Services and railway codes.

No definition in the rules

The CCS (Conduct) Rules, 1964, notified as S.O. 4177 on 12 December 1964, define “Government servant”, “members of family” and other terms in Rule 2, but not misconduct. The CCS (CCA) Rules, 1965 use the word only in the phrase “misconduct or misbehaviour”, in Rule 14(2) for the decision to inquire, Rule 14(3) for the drafting of the charge, and Rule 16 for the memorandum in a minor penalty case.

The courts filled the gap from dictionaries and from the rules’ own structure. Ram Singh (24 July 1992) set out the entry for “misconduct in office” in Black’s Law Dictionary, sixth edition, and P. Ramanatha Aiyar’s Law Lexicon, and then held that the word, though not capable of precise definition, receives its connotation from the context, the delinquency in its performance and its effect on discipline and the nature of the duty. It may involve moral turpitude; it must be improper or wrong behaviour, unlawful behaviour wilful in character, a forbidden act, or a transgression of an established and definite rule of action or code of conduct. It excludes a mere error of judgment, carelessness or negligence.

Ram Singh was a Punjab Police case under Rule 16.2(1) of the Punjab Police Rules, which reserves dismissal for “the gravest acts of misconduct”. A constable found heavily drunk on duty while carrying his service revolver had been dismissed, and the civil courts had set the order aside. The Supreme Court restored the dismissal. The CCS rules contain no definition that differs from it.

The Supreme Court later explained why no closed list is possible. In M.M. Malhotra v. Union of India (2005) 8 SCC 351, decided on 4 October 2005, it said that the acts inconsistent with public service are so varied that “it would be impossible for the employer to exhaustively enumerate such acts and treat the categories of misconduct as closed.” The Court noted that conduct rules almost invariably state a general rule of behaviour first and follow it with specific prohibitions, and used CCS Rule 3(1)(i) to (iii) to illustrate the scheme, although Malhotra itself arose under Section 19 of the Air Force Act, 1950.

General duties and specific prohibitions in the Conduct Rules

Rule 3(1) of the CCS (Conduct) Rules imposes twenty-one general duties, and every one of them can found a charge of misconduct. The first three, which were the whole of Rule 3(1) until 2014, require every government servant at all times to maintain absolute integrity, to maintain devotion to duty, and to “do nothing which is unbecoming of a Government servant.” Notification G.S.R. 845(E) dated 27 November 2014 added clauses (iv) to (xxi).

Three of the 2014 clauses are the ones most often cited in a charge beside the original three. Clause (vi) requires a servant to maintain high ethical standards and honesty. Clause (xviii) requires a servant to refrain from doing anything which is or may be contrary to any law, rules, regulations and established practices. Clause (xix) requires a servant to “maintain discipline in the discharge of his duties and be liable to implement the lawful orders duly communicated to him”, which is the clause behind a charge of refusing a lawful transfer or order.

Rule 3(2) adds a supervisory duty. A servant holding a supervisory post must take all possible steps to ensure the integrity and devotion to duty of everyone under their control, so a supervising officer can be charged for tolerating a subordinate’s misconduct, not only for committing their own.

The specific prohibitions follow. The table lists those that most often appear in a charge sheet, with the rule that creates each.

The list shows why J. Ahmed’s point about exhaustiveness matters. Unauthorised absence from duty appears nowhere in it, yet it is one of the commonest charges in central government. It is charged under the general duties in Rule 3(1) and proceeded against under Rule 14 or Rule 16 of the CCA Rules, while the absence period is regulated separately under the leave rules and, where the authority so orders, treated as dies non.

The J. Ahmed test: blameworthy conduct, not bad performance

The Supreme Court held in Union of India v. J. Ahmed on 7 March 1979 that inefficiency, lack of leadership and indecisiveness are not misconduct, and that gross or habitual negligence can be. The respondent was a Deputy Commissioner and a member of an All India Service, removed after an inquiry into his handling of widespread disturbances in his district. The charges were that he failed to take steps to prevent the disturbances, showed complete lack of leadership, did not visit the scene, did not keep the Government informed, and showed complete inaptitude, lack of foresight and incapacity to take firm and quick decisions.

The bench of D.A. Desai and O. Chinnappa Reddy JJ, reported at AIR 1979 SC 1022 and (1979) 3 SCR 504, read the charges as describing deficiencies in personal ability. It said it was difficult to believe that lack of efficiency or failure to attain the highest standard of administrative ability while holding a high post would themselves constitute misconduct: “If it is so, every officer rated average would be guilty of misconduct.” The appeal was finally dismissed on a separate ground, that the officer had already retired on superannuation when the removal order was made, which made the order void.

Three propositions from the judgment govern central civil servants because the CCS rule is materially the same text as the All India Services (Conduct) Rules, 1954 the Court was construing:

• The code is not exhaustive. “This code of conduct being not exhaustive”, the Court would not hold that only an act contrary to a specific conduct rule is misconduct; conduct that is blameworthy in the context of the Conduct Rules is misconduct.
• A single error is ordinarily not misconduct. “A single act of omission or error of judgment would ordinarily not constitute misconduct”, unless it results in serious or atrocious consequences. The Court cited P.H. Kalyani v. Air France, where two mistakes in checking load-sheets and balance charts, which could have endangered an aircraft and its passengers, were treated as misconduct.
• No guilty mind is needed. The headnote records the holding that misconduct in disciplinary proceedings does not require any form of guilty mind or mens rea, and that gross or habitual negligence in the performance of duty may constitute misconduct without it. The Court declined to follow the Stroud’s Judicial Dictionary definition, relied on by the High Court, that confines misconduct to acts arising from ill motive.

The Conduct Rules later wrote the habitual limb into Rule 3. Explanation I to Rule 3 deems a servant who habitually fails to perform the assigned task within the time set and with the quality expected to be lacking in devotion to duty within the meaning of clause (ii). Occasional poor work stays outside the disciplinary rules; a persistent pattern can be charged. For ordinary inefficiency the service has other instruments: the APAR, the efficiency bar, non-confirmation during probation, and premature retirement under FR 56(j), none of which is a penalty under Rule 11.

Negligence, carelessness and error of judgment

Negligence can become misconduct in three cases: when it is gross, when it is habitual, or when its consequences are serious enough to make the culpability high. J. Ahmed stated the third limb in terms of consequences that are irreparable or damage so heavy that the degree of culpability is very high. Ram Singh excluded “mere” carelessness and negligence, which is the same line drawn from the other side.

The CCA Rules themselves treat negligence as punishable in one clause. Rule 11(iii), a minor penalty, is “recovery from his pay of the whole or part of any pecuniary loss caused by him to the Government by negligence or breach of orders”. A cash-handling or stores lapse that loses public money is therefore charged as negligence and the loss recovered, without any need to show dishonesty.

The Central Vigilance Commission draws the vigilance line at motive. Its Vigilance Manual 2026, dated 27 July 2026, includes gross irregularity or negligence in the discharge of official duties with a dishonest motive in paragraph 5.5.2, an illustrative list of vigilance cases in which major penalty proceedings may be required. The list is illustrative, so it does not exclude other negligence from a major penalty charge; the choice of procedure stays with the disciplinary authority, and the Central Vigilance Commission advises only in the cases within its jurisdiction.

Quasi-judicial orders: the six K.K. Dhawan situations

A servant who passes a wrong order while exercising a quasi-judicial or statutory power is not guilty of misconduct for the wrongness of the order, but can be charged if the conduct falls within six situations the Supreme Court set out in Union of India v. K.K. Dhawan on 27 January 1993. The case, reported at (1993) 2 SCC 56, concerned an income-tax officer issued a charge memorandum under Rule 14 dated 2 May 1989, served on 5 May 1989, over nine assessment orders said to have been completed in undue haste and to have conferred undue favour on the assessees. The Central Administrative Tribunal quashed the memo on the ground that quasi-judicial acts could not be the subject of disciplinary proceedings. The Supreme Court allowed the Government’s appeals.

The bench of L.M. Sharma CJ, S. Mohan and S.P. Bharucha JJ held that disciplinary action can be taken where the officer:

1. acted in a manner that would reflect on their reputation for integrity or good faith or devotion to duty;
2. is shown by prima facie material to have been reckless or guilty of misconduct in the discharge of duty;
3. acted in a manner unbecoming of a government servant;
4. acted negligently, or omitted the prescribed conditions essential for the exercise of the statutory power;
5. acted in order to unduly favour a party; or
6. was actuated by a corrupt motive, however small the bribe.

The Court added that the list is not exhaustive, and that “for a mere technical violation or merely because the order is wrong” and the action falls outside the six, disciplinary action is not warranted. The question in such a case, it said, is not the correctness or legality of the decision but the conduct of the officer in making it. An appellate reversal of an assessment, a licence decision or a pay fixation order is therefore not evidence of misconduct on its own; undue haste, a disregard of mandatory conditions, or a pattern of favour to one party can be.

Conduct outside duty and in private life

Conduct outside official duty can be the subject of disciplinary proceedings where it has a reasonable connection with the nature and conditions of the service, or where it reflects on the servant’s reputation for integrity or devotion to duty. The test comes from S. Govinda Menon v. Union of India, AIR 1967 SC 1274, an All India Services case, which held that an act need not be committed in the course of official duties to be the subject of disciplinary proceedings. K.K. Dhawan relied on it in 1993.

The Conduct Rules reach private life directly in several places: Rule 13-A on dowry, Rule 16 on speculation and borrowing, Rule 17 on habitual indebtedness, Rule 21 on bigamous marriage, and Rule 22(bb), which requires a servant to refrain from consuming any intoxicating drink or drug in a public place. The note under Rule 17 puts the burden on the servant to prove that indebtedness or insolvency arose from circumstances outside their control and not from extravagant or dissipated habits.

Beyond the listed rules, the general duty not to do anything unbecoming applies. A Division Bench of the Andhra Pradesh High Court in Khaja Khan v. Postmaster-General (1975), as quoted by the same court in Union of India v. Mahendra Kumar on 13 December 1984, read Rule 3(1)(iii) as binding a government servant at all times, in office or outside, and rejected a challenge to it as void for vagueness. That is High Court authority, not a Supreme Court holding. The closest Supreme Court decisions on private conduct are Govinda Menon and M.M. Malhotra, where an Air Force officer’s domestic conduct was held “clearly unbecoming of a member of disciplined force” and his compulsory retirement upheld.

Misconduct in an earlier job is treated the same way. Vigilance Manual 2026 paragraph 5.29 allows action for misconduct committed in a previous employment where it has a “rational connection with his present employment” and renders the servant unfit and unsuitable to continue in service.

“Unbecoming of a government servant” and the vagueness objection

Rule 3(1)(iii) can support a charge, but only if the article of charge says what the unbecoming act was. The objection most often raised against it comes from A.L. Kalra v. Project and Equipment Corporation of India (1984) 3 SCC 316, decided on 1 May 1984, where the Supreme Court said that what is unbecoming “may vary with individuals and expose employees to vagaries of subjective evaluation.”

Kalra does not transfer directly to a central civil servant. The public sector corporation’s Conduct Rules, 1975 had a general Rule 4, which included the duty to do nothing unbecoming, and a separate Rule 5 headed “misconduct” that listed the acts of misconduct. The Court held that “Rule 4 does not specify a misconduct” and refused to telescope the general duty into the list; where misconduct entails penal consequences, the employer must specify it with precision. The CCS rules have no separate list, so a CCS charge on Rule 3(1)(iii) is a charge under the rule that sets the standard, and K.K. Dhawan names unbecoming conduct as its third ground for action.

The practical answer is in the drafting. Vigilance Manual 2026 paragraph 5.10.4 requires a charge of lack of devotion to duty, lack of integrity or unbecoming conduct to be clearly spelt out and summarised in the article of charge. A charge that says only that the servant acted in a manner unbecoming, with no act, date or place, is open to the objection the Supreme Court upheld in Sawai Singh v. State of Rajasthan (1986) 3 SCC 454, which struck down charges too vague to answer.

From an act to an article of charge

Rule 14(3) of the CCS (CCA) Rules turns an alleged act into a charge: the disciplinary authority must draw up “the substance of the imputations of misconduct or misbehaviour into definite and distinct articles of charge”. Rule 14(3)(ii) requires, in support of each article, a statement of the imputations containing all relevant facts, including any admission or confession, and a list of the documents and witnesses by which the charge is to be proved. Rule 14(4)(a) requires all of it to be delivered to the servant.

The process usually starts earlier. A complaint or audit finding goes to a preliminary inquiry to see whether there is a prima facie case, and under Rule 14(2) the disciplinary authority decides whether there are grounds for inquiring into the truth of an imputation. If a major penalty is contemplated, the Rule 14 procedure runs through an inquiry officer; if only a minor penalty is contemplated, Rule 16 requires a written memorandum of the imputations and a chance to represent. The differences are set out in major versus minor penalty proceedings.

The Commission’s drafting guidance adds three points. Vigilance Manual 2026 paragraph 5.10.2 states: “A charge should briefly, clearly and precisely identify the misconduct / misbehaviour.” Paragraph 5.10.3, a set of drafting guidelines, advises that the nature of the misconduct, such as the conduct rule breached, to be stated at the end of the article, after the act itself. Paragraph 5.11 states that the statement of imputations should mention the conduct expected or the rule violated.

Sexual harassment is the one category with its own inquiring body. The proviso to Rule 14(2) deems the complaints committee constituted in each ministry, department or office to be the inquiring authority for a complaint of sexual harassment within the meaning of Rule 3-C of the Conduct Rules, which provides that “No Government servant shall indulge in any act of sexual harassment of any woman at any work place.” The wider statutory scheme is in the Sexual Harassment of Women at Workplace Act, 2013.

Proving misconduct

A charge of misconduct is proved on a preponderance of probability, the civil standard, not beyond reasonable doubt. The Supreme Court held in State of Andhra Pradesh v. S. Sree Rama Rao, AIR 1963 SC 1723, that the strict rules of the Evidence Act do not apply to a departmental inquiry. The finding must still rest on evidence recorded in the inquiry, and the principles of natural justice require the servant to see the evidence and answer it.

The difference in standard is why the same act can lead to an acquittal in a criminal court and a penalty in the department. A charge under the Prevention of Corruption Act, 1988 must be proved beyond reasonable doubt; the parallel departmental charge of lack of integrity under Rule 3(1)(i) needs only the civil standard.

A conviction removes the need for an inquiry. Rule 19(i) of the CCS (CCA) Rules, which mirrors clause (a) of the second proviso to Article 311(2) of the Constitution, allows the disciplinary authority to impose a penalty on the ground of conduct which has led to a conviction on a criminal charge without holding an inquiry, after considering the circumstances of the case. The first proviso to Rule 19 provides that the servant may be given an opportunity of representing on the proposed penalty before the order is made; it is permissive, not mandatory.

Choosing the penalty for proved misconduct

Rule 11 of the CCS (CCA) Rules sets out ten penalties and, with one exception, leaves the disciplinary authority to match the penalty to the misconduct. The five minor penalties are censure, withholding of promotion, recovery of pecuniary loss, a one-stage reduction for up to three years, and withholding of increments. The five major penalties are a longer reduction in the pay scale, reduction in rank, compulsory retirement, removal and dismissal.

The exception is corruption. The first proviso to Rule 11 requires removal under clause (viii) or dismissal under clause (ix) in every case where a charge of possessing assets disproportionate to known sources of income, or of accepting any gratification other than legal remuneration as a motive or reward for an official act, is established. The second proviso allows any other penalty “in any exceptional case and for special reasons recorded in writing”. Ram Singh, a drunkenness case, observed in passing that “a single act of corruption is sufficient to award an order of dismissal” under the police rules it construed.

For everything else the choice is reviewed only for proportionality. The Supreme Court held in B.C. Chaturvedi v. Union of India (1995) 6 SCC 749 that a court or tribunal does not substitute its own view of the penalty unless the one imposed shocks the conscience, and even then ordinarily remits the question to the authority. The speaking order imposing the penalty must still show that the authority considered the gravity of each proved charge.

A proved charge of misconduct also costs the servant outside the penalty. Under DoPT OM No. 22011/4/2007-Estt.(D) dated 28 April 2014, an officer under a penalty whom the Departmental Promotion Committee finds fit is promoted only after the currency of the penalty ends, except for censure and recovery of pecuniary loss, and paragraph 8(l) of DoPT OM No. 104/33/2024-AVD-IA dated 9 October 2024 denies vigilance clearance for three years after the currency of a minor penalty ends.

Grave misconduct and pension

After retirement the test changes from misconduct to grave misconduct or negligence. Rule 8(1) of the CCS (Pension) Rules, 2021, as substituted by G.S.R. 770(E) of 7 October 2022, lets the President (where the President was the appointing authority), the Secretary of the administrative Ministry or Department, or the Comptroller and Auditor-General for the Indian Audit and Accounts Department withhold a pension or gratuity, or withdraw a pension, in full or in part, permanently or for a period, and to recover a pecuniary loss, if in any departmental or judicial proceedings the pensioner is “found guilty of grave misconduct or negligence during the period of service”, including service on re-employment. The UPSC must be consulted before a final order passed by the President, and a pension cut in part may not fall below the minimum pension under Rule 44.

Rule 7 is a separate power. It makes future good conduct an implied condition of every pension, and allows the appointing authority to withhold or withdraw a pension where the pensioner is convicted of a serious crime or found guilty of grave misconduct, and in a case not resting on a conviction Rule 7(3) requires a show-cause notice and consideration of the reply first. Rule 7(4) makes a breach of the undertaking given by a retiree of an intelligence or security organisation, not to publish material about the organisation without clearance, grave misconduct by deeming.

Neither rule defines grave misconduct. Proceedings not begun in service can still be started after retirement under Rule 8(2)(c), but only with the sanction of the Rule 8(1) competent authority and only for an event within four years before the proceedings are instituted. Proceedings begun in service continue after retirement as proceedings under Rule 8(2)(a), but a Rule 16 minor penalty case continued after retirement has no effect on pension or gratuity under Rule 8(2)(b). Recovery from gratuity is covered in withholding and recovery from gratuity.

All India Services and railway codes

The All India Services and the railways state the same core duty in near-identical words, and the Supreme Court tests apply to both. Rule 3(1) of the All India Services (Conduct) Rules, 1968 provides that every member of the Service shall at all times maintain absolute integrity and devotion to duty and “shall do nothing which is unbecoming of a member of the Service.” Rule 3(1)(iii) of the Railway Services (Conduct) Rules, 1966 reads “do nothing which is unbecoming of a railway servant.”

The All India Services rule has two consequences for this subject. J. Ahmed and Govinda Menon were both All India Services cases, so their holdings apply to IAS, IPS and IFoS officers directly and to CCS servants by the materially identical wording of Rule 3. And sexual harassment for All India Services members is governed by the AIS (Prevention of Sexual Harassment) Regulations, 1998, framed under Rule 3 of the 1968 Rules.

Common misreadings of misconduct

• “Only a breach of a specific conduct rule is misconduct.” J. Ahmed (1979) held the code is not exhaustive, and M.M. Malhotra (2005) held the categories cannot be closed.
• “Misconduct needs a dishonest motive.” J. Ahmed rejected the ill-motive definition from Stroud’s; gross or habitual negligence can be misconduct without any guilty mind.
• “A poor APAR can be the basis of a charge.” Lack of efficiency or ability is not misconduct under J. Ahmed; only the habitual failure described in Explanation I to Rule 3 is.
• “An order reversed on appeal proves misconduct.” K.K. Dhawan (1993) excludes a merely wrong order; one of its six situations has to be shown.
• “Private life is outside the rules.” Rules 13-A, 16, 17, 21 and 22 reach it, and Govinda Menon allows action where the act connects with the service.
• “An acquittal ends the departmental case.” The department proves its charge on preponderance of probability, a lower standard than the criminal court’s.
• “Every corruption case must end in dismissal.” Removal or dismissal is required by the first proviso to Rule 11 once the charge is established, but the second proviso allows another penalty for special reasons recorded in writing.

Related Articles

• CCS (Conduct) Rules, 1964
• CCS (Classification, Control and Appeal) Rules, 1965
• Charge sheet and articles of charge
• Departmental inquiry
• Preliminary inquiry
• Major versus minor penalty proceedings
• Minor penalty
• Withholding of increment
• Reduction in rank
• Compulsory retirement
• Dismissal and removal from service
• Disciplinary authority
• Inquiry officer
• Presenting officer
• Written statement of defence
• Speaking order
• Common proceedings
• Penalty proportionality
• Principles of natural justice
• Suspension
• Dies non
• Appeal, review and revision under the CCS (CCA) Rules
• Central Administrative Tribunal
• Article 311
• Doctrine of pleasure
• Article 309
• Prevention of Corruption Act, 1988
• Disproportionate assets
• Central Vigilance Commission
• Chief Vigilance Officer
• Vigilance clearance
• Immovable property return
• Complaints committee on sexual harassment
• Sexual Harassment of Women at Workplace Act, 2013
• APAR
• Efficiency bar
• Probation in central government
• Departmental Promotion Committee
• Sealed cover procedure
• Income-tax officer
• CCS (Pension) Rules, 2021
• Withholding of pension
• Withholding and recovery from gratuity
• Compassionate allowance
• All India Services
• All India Services (Conduct) Rules, 1968
• All India Services (Discipline and Appeal) Rules, 1969
• Railway Servants (Discipline and Appeal) Rules, 1968
• Union Public Service Commission
• Department of Personnel and Training

External references

• CCS (Conduct) Rules, 1964, Department of Personnel and Training
• CCS (CCA) Rules, 1965, Department of Personnel and Training
• DoPT Office Memorandum of 26 March 2024, Handling of Disciplinary Proceedings in respect of Central Civilian employees
• Central Vigilance Commission
• All India Services (Conduct) Rules, 1968, IPS portal
• Railway Services (Conduct) Rules, 1966, Railway Board

References

1. Central Civil Services (Conduct) Rules, 1964, S.O. 4177 dated 12 December 1964, DoPT compilation as amended up to 31 December 2014: Rules 2, 3(1), 3(2) and Explanation I, 3-A, 3-C, 4, 5, 7, 11, 13, 13-A, 15 to 18, 20, 21 and 22; G.S.R. 845(E) dated 27 November 2014 (clauses (iv) to (xxi) of Rule 3(1)); G.S.R. 531(E) dated 29 July 2019 (Rule 13 gift limits).
2. Central Civil Services (Classification, Control and Appeal) Rules, 1965, DoPT compilation updated to 15 October 2018: Rule 11 and its provisos, Rule 14(2) and its proviso, 14(3), 14(4), Rule 16 and Rule 19.
3. Central Civil Services (Pension) Rules, 2021: Rules 7, 8(1), 8(2)(a), 8(2)(b), 41 and 44.
4. Union of India v. J. Ahmed, Supreme Court, decided 7 March 1979, AIR 1979 SC 1022, (1979) 3 SCR 504.
5. State of Punjab v. Ram Singh Ex-Constable, (1992) 4 SCC 54, decided 24 July 1992; Union of India v. K.K. Dhawan, (1993) 2 SCC 56, decided 27 January 1993.
6. A.L. Kalra v. Project and Equipment Corporation of India Ltd., (1984) 3 SCC 316, decided 1 May 1984; M.M. Malhotra v. Union of India, (2005) 8 SCC 351, decided 4 October 2005.
7. S. Govinda Menon v. Union of India, AIR 1967 SC 1274; State of Andhra Pradesh v. S. Sree Rama Rao, AIR 1963 SC 1723; Sawai Singh v. State of Rajasthan, (1986) 3 SCC 454; B.C. Chaturvedi v. Union of India, (1995) 6 SCC 749.
8. Union of India v. Mahendra Kumar, Andhra Pradesh High Court, decided 13 December 1984, quoting Khaja Khan v. Postmaster-General, 1975 (1) An. W.R. 64.
9. Central Vigilance Commission, Vigilance Manual 2026, dated 27 July 2026, Chapter V, paragraphs 5.5.2, 5.10.2, 5.10.3, 5.10.4, 5.11 and 5.29.
10. All India Services (Conduct) Rules, 1968, Rule 3(1); All India Services (Prevention of Sexual Harassment) Regulations, 1998; Railway Services (Conduct) Rules, 1966, Rule 3(1)(iii); DoPT OM No. 104/33/2024-AVD-IA dated 9 October 2024.