Quasi-judicial negligence alone does not justify disciplinary action absent extraneous influence or improper motive.

Disciplinary action against a quasi-judicial authority is not justified by every erroneous decision, error of judgment, or mere negligence in adjudication. The controlling distinction is between a simple mistake made in the exercise of judicial or quasi-judicial functions and culpable misconduct involving extraneous considerations, undue favour, quid pro quo, or improper motive. A bare allegation that the authority acted negligently or recklessly in passing an order, without any charge of outside influence or favouritism, does not amount to misconduct under the relevant conduct rules and cannot sustain disciplinary proceedings.

---

---

Issues: Whether a quasi-judicial authority could be subjected to disciplinary proceedings on a mere charge of negligence or recklessness in passing an adjudicatory order.

Analysis: The governing principle was that disciplinary action against an exercising quasi-judicial powers is not attracted by every error of judgment or mere negligence. The controlling distinction drawn from the Supreme Court authorities was between a simple mistake in adjudication and culpable negligence or misconduct accompanied by extraneous considerations, undue favour, or some improper motive. A mere allegation that the authority passed a wrong order with negligence or recklessness, without any further charge of favouritism, quid pro quo, or other outside influence, does not constitute misconduct under the relevant conduct rules so as to justify disciplinary proceedings.

Conclusion: A mere charge of negligence or recklessness in the exercise of quasi-judicial functions, standing alone and unaccompanied by allegations of extraneous consideration or undue favour, cannot sustain disciplinary proceedings against the authority.

---