MUHAMMAD NIAZ KHAN vs R.P — 2025 PLC(CS) 1477 SUPREME-COURT

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MUHAMMAD NIAZ KHAN VS R.P.O. SHEIKHUPURA REGION AT LAHORE S.5---Punjab Service Tribunal---Powers---Principle of proportionality---Scope---Petitioner (Sub-Inspector) was proceeded against on allegations pertaining to faulty investigation by him, and was awarded major penalty of dismissal from service; on departmental appeal, the penalty was reduced to a two-stage reduction in pay while he was reinstated into service---Petitioner approached the Punjab Service Tribunal ('Tribunal'), seeking reinstatement with effect from the date of his original dismissal, along with all consequential benefits, however, the Tribunal modified the penalty from a two-stage to a one-stage reduction in pay('impugned order')---Validity---Record revealed that, through impugned order, the Tribunal found that although an investigation had been conducted, yet the prosecution failed to produce even a shred of evidence to substantiate the allegations---Despite said categorical findings, the Tribunal opted merely to reduce the penalty, rather than exonerate the petitioner---It appeared that the Tribunal relied, albeit implicitly, on the principle of proportionality, finding the original penalty disproportionate to the alleged misconduct---However, this application was both legally flawed and logically inconsistent with its own conclusion when no misconduct was established---Tribunal failed to properly exercise its discretion under Section 5 of the Punjab Service Tribunals Act, 1974, which empowered it to confirm, set aside, vary, or modify impugned orders---While the Tribunal has authority to vary the punishment in appropriate cases, such discretion must be exercised judiciously grounded in the record, legal standards, and principles of fairness---Judicial interference with disciplinary penalties is only justified where the penalty is arbitrary, perverse, or based on irrelevant considerations---Once the Tribunal found that the allegations were wholly unsubstantiated, the only lawful outcome was to exonerate the petitioner---Proportionality promotes a stable and systematic method of constitutional adjudication---Courts employing said approach are expected to articulate clearly the reasoning behind their decisions at each stage of the analysis thereby enhancing transparency, accountability, and legitimacy in judicial reasoning---Proportionality must, therefore, be applied with discipline, care, and sensitivity to context, particularly where fundamental rights and human dignity are at stake---Thus, the impugned order was untenable in both law and fact---Once the Tribunal determined that the charges were unsubstantiated, the only legally viable course was to exonerate the petitioner---The imposition of any penalty, absent proven misconduct, constitutes a violation of natural justice and results in a manifest miscarriage of justice---The Tribunal's decision, being internally inconsistent and contrary to constitutional norms, was accordingly set aside---The petitioner stood exonerated and was directed to be reinstated in service from the date of his original dismissal, with all consequential benefits---Accordingly, petition was converted into an appeal and was allowed.

MUHAMMAD NIAZ KHAN vs R.P — 2025 PLC(CS) 1477 SUPREME-COURT

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