Disciplinary action against quasi-judicial officers requires objective proof of improper motive, not mere legal error.

Disciplinary proceedings against a quasi-judicial officer are said to be permissible only where objective material shows culpability, ulterior motive, dishonesty, or misuse of power; a mere legal error or difference on the merits is insufficient. The note further states that a charge memorandum must disclose prima facie verifiable facts, not inference or suspicion, and that allegations of undue haste or collusion need factual support such as correspondence or other objective basis. On the stated facts, the memorandum was considered unsupported by sufficient material and liable to be quashed, with consequential relief including promotion consideration.

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Issues: (i) Whether disciplinary proceedings could be initiated against an officer for acts done in the discharge of quasi-judicial functions; (ii) Whether the charge memorandum disclosed prima facie material justifying the proposed disciplinary action.

Issue (i): Whether disciplinary proceedings could be initiated against an officer for acts done in the discharge of quasi-judicial functions.

Analysis: Quasi-judicial officers require a measure of independence, but they do not enjoy absolute immunity. Disciplinary action in relation to quasi-judicial acts is permissible only with great caution and close scrutiny, and only where the record discloses culpability, ulterior motive, dishonesty, or an improper purpose. A mere difference of opinion on the merits of the decision or an alleged error of law is not enough.

Conclusion: The initiation of disciplinary proceedings is legally permissible only where adequate material exists to show misuse of power for wrongful gain or other improper motive; otherwise, it is not justified.

Issue (ii): Whether the charge memorandum disclosed prima facie material justifying the proposed disciplinary action.

Analysis: The charge memorandum rested on allegations of undue haste and collusion in disposal of an appeal, but the record showed that the appeal had been pending for a long time, repeated official communications had pressed for early hearing, and the assessee itself had sought expeditious disposal. The material also did not show any direct correspondence or objective basis suggesting collusion or dishonest intent. The allegations were therefore based on inference and imagination rather than verifiable facts.

Conclusion: The charge memorandum did not disclose sufficient prima facie material and was liable to be quashed.

Final Conclusion: The disciplinary proceedings could not be sustained on the facts found, and the applicant was entitled to relief including consequential consideration of promotion.

Ratio Decidendi: Disciplinary proceedings against a quasi-judicial officer can proceed only where the charge is supported by objective, verifiable material showing culpability, improper motive, or misuse of power; a mere alleged legal error or unfavorable decision does not suffice.

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