Threshold review of disciplinary charges is limited to the face of the allegations; quasi-judicial conduct may still warrant inquiry.

A disciplinary charge-sheet against an income-tax officer for actions taken in quasi-judicial functions may be quashed at the threshold only if, on its face, it discloses no misconduct or is contrary to law. Judicial review at the stage of framing charges is confined to the face of the allegations; the truth, sufficiency, or evidentiary weight of the charges cannot be tested, and the disciplinary authority's view cannot be substituted. Allegations of lack of integrity, recklessness, negligence, undue favour, or corrupt motive can support proceedings even where they arise from judicial or quasi-judicial orders. Threshold interference was impermissible, and the disciplinary inquiry had to proceed.

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Issues: Whether a disciplinary charge-sheet against an income-tax for actions taken while exercising quasi-judicial functions could be quashed at the threshold on the ground that the charges were unsustainable on merits.

Analysis: The Court held that at the stage of framing of charges, judicial review is confined to examining whether the allegations, if taken at face value, disclose misconduct or are contrary to law. The Tribunal had no jurisdiction to test the truth of the charges, assess the evidence, or substitute its own view for that of the disciplinary authority. The Court further held that disciplinary proceedings can validly be initiated even in respect of conduct connected with judicial or quasi-judicial orders where the allegations suggest lack of integrity, recklessness, negligence, undue favour, or corrupt motive. The Tribunal had exceeded its jurisdiction by quashing the memorandum on an assessment of disputed material.

Conclusion: The challenge to the charge-sheet could not be sustained and the disciplinary inquiry was required to proceed.

Final Conclusion: Threshold interference in disciplinary matters was impermissible where the charges, on their face, disclosed actionable misconduct in the discharge of quasi-judicial duties.

Ratio Decidendi: A disciplinary charge-sheet may be interfered with only if, on its face, it discloses no misconduct or is contrary to law; the truth or sufficiency of the allegations, including those arising from quasi-judicial acts, must be left to the disciplinary inquiry.

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