21-05-2025
Supreme Court strikes down Madhya Pradesh order on forest officers' performance appraisal
Supreme Court
BHOPAL: The
Supreme Court of India
has struck down a
Madhya Pradesh government
order dated 29 June 2024 regarding the
Performance Appraisal Reports
(PAR) of
Indian Forest Service
(IFS) officers. The Court ruled that the order violated established
judicial precedents
and the autonomy of the Forest Department under the All-India Services framework.
The Supreme Court held that the Madhya Pradesh government's directive, which required Indian Administrative Service (IAS) officers such as District Collectors and Divisional Commissioners to provide inputs into the appraisal of IFS officers, was illegal.
The bench, comprising Chief Justice B R Gavai and Justice Augustine George Masih, stated that this practice undermines both administrative propriety and judicial authority.
The Court reiterated that performance evaluations of IFS officers up to the rank of Additional Principal Chief Conservator of Forests (APCCF) must be conducted solely by their immediate superiors within the Forest Department, as per earlier Court rulings.
Delivering the judgment in a set of applications filed under the long-running T N Godavarman Thirumulpad v. Union of India case, the Court noted that the Madhya Pradesh order blatantly disregarded its own directions passed in 2000 and reiterated in 2004.
These directions, further clarified by the Ministry of Environment and Forests (MoEF) and the Department of Personnel and Training (DoPT), have been consistently followed by all other Indian states — with Madhya Pradesh standing out as the lone violator.
The judgment pointedly declared that allowing officers from a different service — particularly those of equal or lower rank — to assess IFS officers was not just procedurally flawed but also contemptuous in nature.
'We have no hesitation to hold that the impugned G.O. is rather contemptuous in nature... issued without even seeking clarification or modification of this Court's orders,' the bench stated.
It noted that such orders ignored long-established principles of public administration that require performance reviews to be conducted by officers with real supervisory engagement and departmental familiarity.
The Court conducted an exhaustive analysis of the legal framework governing All India Services, including the All-India Services Act, 1951, and the Confidential Rolls and Performance Appraisal Rules of 1970 and 2007 respectively.
It emphasised that these laws and associated judicial interpretations mandate that the reporting, reviewing, and accepting authorities for IFS officers must be individuals of higher rank within the same service — ensuring both accountability and subject-matter understanding.
Revisiting the 2000 Santosh Bharti v. State of Madhya Pradesh ruling, the court reaffirmed that officers such as the Assistant Conservator of Forests, Divisional Forest Officer, Conservator of Forests, Chief Conservator, and APCCF must be appraised strictly within the Forest hierarchy — with the Principal Chief Conservator of Forests (PCCF) being the only exception, as there is no higher-ranking IFS officer above them.
Even in such cases, the reporting authority must be someone familiar with the officer's work and higher in rank.
Further strengthening its position, the bench cited landmark rulings such as State of Haryana Vs P C Wadhwa and State of Assam Vs Binod Kumar, which reinforced the requirement that reporting authorities must be from within the same department and of higher rank. These principles, the Court said, remain valid despite changes in rules and are fundamental to a fair and objective appraisal system.
The judgment also acknowledged that while IAS officers may oversee certain development schemes — such as MGNREGA, land acquisition, and tourism projects — forest officers remain primarily responsible for conservation, enforcement of environmental law, and forestry operations. Accordingly, inputs from District Collectors or Divisional Commissioners, if any, may be submitted on a separate sheet and considered as supplementary remarks — but cannot form the basis of the formal PAR process.
The Court issued clear directives: the impugned 29 June 2024 government order was quashed, and the state was directed to reframe its rules within one month in strict compliance with the 2000 judgment and clarifications issued by MoEF and DoPT.
While the court observed that the state's actions were close to contempt, it refrained from initiating proceedings due to the fair conduct of the State's legal representatives.
Forest officers have welcomed the ruling, seeing it as a vital affirmation of institutional independence and professionalism in environmental governance.
