https://indianmasterminds.com

ADVERTISEMENT
ADVERTISEMENT

CISF Constable Prabhu Nath Yadav Case: High Court Orders Salary Recalculation After Illegal Double Penalty

The Allahabad High Court delivered a landmark ruling that a CISF constable cannot face multiple punishments for the same misconduct. The court held that denying efficiency bar increments after already imposing a minor penalty violates foundational principles of justice.
CISF constable Prabhu Nath Yadav case
Indian Masterminds Stories

Lucknow: In a significant judicial pronouncement underscoring the fundamental legal doctrine of double punishment prohibition, the Allahabad High Court has granted relief to a Central Industrial Security Force (CISF) constable, ruling that no government employee can be penalized more than once for the same misconduct. 

The decision brings clarity to disciplinary jurisprudence in the context of service law and efficiency bar denial. 

The Division Bench reiterated that when a minor punishment has already been imposed for a particular act of misconduct, any additional or aggravated penalty rising from that same misconduct violates the legal principle that a person should not face multiple punishments for the same act. 

Background of the CISF Constable Prabhu Nath Yadav Case

The petitioner, Prabhu Nath Yadav, was appointed as a CISF constable in 1987. After several years of service, he received an increment to his basic pay. However, in 1991, an Efficiency Board declared him “Not Yet Fit”, thereby withholding his efficiency bar increment — a vital step that increases pay and pension benefits. The denial was based on an alleged poor service record. 

Read also: UP Police Wrong Law Conversion Case: Allahabad High Court Flags Serious Lapse After Chhattisgarh Act Used in UP FIR

Prior to this efficiency bar denial, the constable had already been punished by withholding two annual increments — a minor penalty — for misconduct and was also fined seven days’ pay. 

Although the petitioner was later declared “fit” in 1994 and granted the withheld increments, he had already lost three years’ benefits compared to similarly situated personnel. This has had a continuing impact on his overall salary and, later, his pension. 

CISF Constable Prabhu Nath Yadav Case: Efficiency Bar Denial as Punishment

The principal legal question before the High Court was whether denial of the efficiency bar — in consequence of past misconduct — amounted to an additional punishment for the same misconduct that had already been punished earlier.

Under service rules, crossing the efficiency bar is dependent on performance and fitness at specified intervals. It is intended to reward satisfactory performance, experience, and seniority. However, according to the court, denial of this benefit should be strictly tied to actual inefficiency in service — not merely past minor misconduct for which punishment had already been inflicted. 

Judgment of the Allahabad High Court in CISF Constable Prabhu Nath Yadav Case

Justice Subhash Vidyarthi delivered the judgment. The High Court held that:

> “No person can be punished more than once for the same misconduct.”

Once the petitioner suffered the punishment of withheld increments and pay fine, denying him the efficiency bar — which had a lasting and cumulative impact on pay and pension — effectively amounted to a second and major punishment for the same misconduct. 

The court clarified that efficiency bar denial should only be applied where the service record clearly reflects inefficiency unrelated to the misconduct already punished. 

The mere label of “Not Yet Fit”, without a demonstrated adverse effect on job performance, was insufficient justification for withholding the efficiency bar. 

Since the only evidence relied upon was previously punished minor misconduct, the court found that denial of the efficiency bar was unjustified and amounted to punishing the petitioner again for the same offense. 

Court’s Direction & Relief Granted

Based on these findings, the Allahabad High Court allowed the writ petition and directed that:

  • The petitioner’s salary and related benefits be recalculated;
  • All arrears be paid with interest;
  • The cumulative impact on pension benefits will be remedied.

This decision not only corrects a long-standing financial disparity for the petitioner but also affirms service members’ rights under constitutional and statutory protections against repeated punishment for identical misconduct. 

Read also: Supreme Court Upholds Dismissal of CISF Personnel for Second Marriage, Stresses Discipline in Forces


Indian Masterminds Stories
ADVERTISEMENT
ADVERTISEMENT
Related Stories
ADVERTISEMENT
ADVERTISEMENT
NEWS
cm
CM Hemant Soren Pays Tribute to Dishom Guru Shibu Soren on 82nd Birth Anniversary, Focuses on Education and Youth
Uttar Pradesh yogi
Uttar Pradesh IAS Promotions 2026: 17 Officers Elevated, 5 Including Sanjay Prasad Become Additional Chief Secretaries
drdo
DRDO Successfully Tests Third-Generation MPATGM with Top-Attack Capability Against Moving Target
bob
Bank of Baroda Strengthens Partnership with Mizoram Govt to Boost Development and Financial Inclusion
Ex-IPS Sanjay Pandey
Who Is Ex-DGP Sanjay Pandey? 1986-Batch IPS Officer Allegedly Conspired Against Fadnavis and Shinde in Maharashtra ULC Scam
bihar
Bihar Upgrades Rural Roads to 2 Lanes Under ‘Saat Nishchay-3’, Connecting Over 1.19 Lakh Villages
Bihar Agriculture Department
Bihar Government Launches Lady Rosetta Potato Cultivation with 75% Subsidy to Boost Farmers’ Income
Janata Darshan Gorakhpur
UP CM Yogi Holds Janata Darshan, Promises Strict Action on Encroachments and Financial Aid for Patients
ADVERTISEMENT
ADVERTISEMENT
Videos
Col M Shashidhar
 Lessons From Operation Sindoor & Operation Absolute Resolve 
Dr
Why an MBBS Doctor Chose IAS and Cleared UPSC in Her First Attempt | Dr. Akshita Gupta Video Interview
Rohit Nandan IAS Travel Air
How To Bring Air Travel Industry Back on Track? | Insights from Former Civil Aviation Joint Secy Rohit Nandan
ADVERTISEMENT
UPSC Stories
Bhilai Steel Plant Diploma Engineer to CGPSC 2024 Deputy Collector – Yashwant Dewangan
Lost Father at 17, Worked Full-Time: Bhilai Steel Plant Diploma Engineer to CGPSC 2024 Deputy Collector – Yashwant Dewangan
Yashwant Kumar Dewangan, a BSP diploma engineer from Korba, overcame personal and professional challenges...
Aditi Chhaparia IFS UPSC
What UPSC Aspirants Can Learn from IFS Officer Aditi Chhaparia’s Measured Approach
What UPSC aspirants can learn from IFS officer Aditi Chhaparia (AIR 97)—her preparation strategy, mindset,...
Dev Tomar IRMS
His Grandfather Was a Rebel Dacoit, but Dev Tomar’s Father Chose Education—and That Changed Everything
Dev Tomar, from a rebel dacoit grandfather to an IRMS officer, cleared UPSC 2024 (AIR 629) after five...
Social Media
One-Horned Rhino Calf
Watch: First One-Horned Rhino Calf of 2026 Takes Birth at Jaldapara National Park, IFS Officer Shares Rare Footage
A newborn one-horned rhinoceros calf was spotted at Jaldapara National Park on January 1, 2026. IFS officer...
venomous banded krait
Rare Night Encounter: IFS Officer Spots Highly Venomous Banded Krait During Forest Patrol, Internet Amazed
An IFS officer’s night patrol video of a highly venomous banded krait has gone viral, highlighting India’s...
elephant rescue Karnataka
Heroic Karnataka Elephant Rescue: How a 28-Hour “Impossible Mission” Became a Triumph of Wildlife Care, IFS Parveen Kaswan Shares Video
A trapped elephant was rescued after 28 hours in Karnataka through a massive, expertly coordinated Forest...
ADVERTISEMENT
ADVERTISEMENT
ADVERTISEMENT
Latest
cm
CM Hemant Soren Pays Tribute to Dishom Guru Shibu Soren on 82nd Birth Anniversary, Focuses on Education and Youth
Uttar Pradesh yogi
Uttar Pradesh IAS Promotions 2026: 17 Officers Elevated, 5 Including Sanjay Prasad Become Additional Chief Secretaries
ADVERTISEMENT
ADVERTISEMENT
ADVERTISEMENT
ADVERTISEMENT
ADVERTISEMENT
ADVERTISEMENT
ADVERTISEMENT
Videos
Col M Shashidhar
Dr
Rohit Nandan IAS Travel Air
ADVERTISEMENT
ADVERTISEMENT