Recorded reason for compulsory retirement must be exact; impairment of efficiency was sufficient and mala fides were not proved.

Compulsory retirement under Note (1) to Rule 8 of the Revised Pension Rules, 1950 required the exact reason to be recorded in writing, and a note stating impairment of efficiency satisfied that requirement. The expression "such as" was treated as illustrative, so the listed public grounds were not exhaustive, and a separate observation that a formal charge of inefficiency was undesirable was only a prefatory opinion, not an additional reason. The record of persistent adverse material and deterioration in service efficiency did not establish mala fides. On that reasoning, the retirement order was upheld and the challenge failed.

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Issues: (i) Whether the compulsory retirement order was in strict compliance with Note (1) to Rule 8 of the Revised Pension Rules, 1950. (ii) Whether the order was liable to be struck down as mala fide.

Issue (i): Whether the compulsory retirement order was in strict compliance with Note (1) to Rule 8 of the Revised Pension Rules, 1950.

Analysis: Note (1) restricts compulsory retirement to public grounds and requires the exact reason to be recorded in writing. The expression "such as" shows that the stated grounds are illustrative and not exhaustive. A separate recital that it was not desirable to frame a formal charge of inefficiency is not an additional reason but only an opinion preceding the decision. The recorded note stating that retirement was proposed for impairment of efficiency in the work assigned to the employee satisfied the requirement of recording the exact reason.

Conclusion: The retirement order was in strict and full compliance with Note (1) to Rule 8, and it could not be invalidated on this ground.

Issue (ii): Whether the order was liable to be struck down as mala fide.

Analysis: The service record over several years contained adverse material and showed persistent deterioration in efficiency. The decision was based on the overall confidential record and the relevant administrative assessment, not merely on the conduct of the officer against whom grievance was alleged. The material did not establish mala fides in the making of the compulsory retirement order.

Conclusion: The challenge based on mala fides failed.

Final Conclusion: The High Court's judgment was set aside, the writ petition was dismissed, and the compulsory retirement order was upheld.

Ratio Decidendi: Where a rule requires the exact reason for compulsory retirement to be recorded in writing, a recorded ground stating impairment of efficiency is sufficient, and the stated grounds may be illustrative rather than exhaustive if the rule uses qualifying language such as "such as".

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