In a sharp rebuke to the Madhya Pradesh government, the Supreme Court on Wednesday quashed a government order that had empowered IAS officers to review the performance appraisal reports (Annual Confidential Reports or ACRs) of Indian Forest Service (IFS) officers, calling the move “contemptuous” and a violation of previous Supreme Court rulings.
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A bench comprising Chief Justice D.Y. Chandrachud and Justice Augustine George Masih was hearing petitions that questioned whether IAS officers — such as district collectors or senior administrative officers — could legally act as reporting, reviewing, or accepting authorities for IFS officers working within the forest department.
The bench ruled that the June 29, 2024, Government Order (GO) issued by the Madhya Pradesh government was in direct violation of the Supreme Court’s landmark ruling dated September 22, 2000, which had laid down clear guidelines regarding performance appraisals within the All India Services.
“We have no hesitation to hold that the impugned GO is rather contemptuous in nature… issued without even seeking clarification or modification of this court’s earlier ruling,” said the Chief Justice, who authored the verdict.
In its 2000 ruling, the apex court had clarified that:
- IFS officers up to the rank of Additional Principal Chief Conservator of Forests must have their ACRs reviewed only by immediate superior officers within the forest department.
- Only for Principal Chief Conservators of Forests, who have no superior within the IFS, can the reporting authority belong to a different service.
The court observed that all other states had complied with the 2000 ruling, while Madhya Pradesh had defied it, continuing with the practice of letting IAS officers record and review ACRs for IFS officers.
“It appears that, while other states were adhering to the practice of internal service reviews, Madhya Pradesh was not following this established system,” the bench noted.
Though the top court expressed that it could have initiated contempt proceedings against those responsible for the GO, it chose not to, stating instead:
“However, we refrain ourselves from doing so. The said GO being in violation of the directions of this court is liable to be quashed and set aside.”
Directions to Madhya Pradesh Government
The court has directed the Madhya Pradesh government to reframe its rules within one month, strictly adhering to the 2000 Supreme Court ruling. It emphasized that IFS officers’ appraisals must be conducted within the forest hierarchy, and inputs from district collectors — if any — must be recorded separately and reviewed by forest department superiors, not IAS officers.
The bench also cited a clarification from the Department of Personnel and Training (DoPT) issued in September 2004, which had reaffirmed that the 2000 ruling applied to IFS officers working within the forest department, not those on deputation or posted outside.
This verdict serves as a significant reaffirmation of the service-wise separation of supervisory roles in India’s civil services and emphasizes the judiciary’s commitment to upholding cadre autonomy and institutional integrity.
Also Read: SC Steps in to Resolve Dispute Over IFS Performance Appraisals by IAS Officers
