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Issues: Whether disciplinary proceedings could be initiated against a government servant for acts done while exercising quasi-judicial powers where the charge alleged irregular and hasty assessments made to confer undue favour on assessees.
Analysis: A government servant is not immune from disciplinary action merely because the impugned act occurred in the course of quasi-judicial decision-making. The controlling consideration is not the correctness of the order, which may be tested in appeal or revision, but whether the conduct reflects on integrity, devotion to duty, good faith, or amounts to recklessness, misconduct, negligence, abuse of power, or an attempt to unduly favour a party. Earlier decisions were distinguished on their facts because they did not involve allegations of culpable conduct such as favouritism or improper motive. On the pleaded charge, the allegation that the assessments were completed in an irregular manner, in undue haste, and with a view to confer undue favour brought the case within the zone where disciplinary action was permissible.
Conclusion: Disciplinary proceedings were held maintainable against the respondent, and the challenge to the charge memorandum could not succeed.