SARDAR PRAKASH SINGH BADAL vs V.K. KHANNA — C.A. No. 6964/2000

Case Summary: State of Punjab v. V.K. Khanna (2000) Court Decision: The Supreme Court dismissed the State of Punjab's appeal and upheld the High Court's decision quashing the disciplinary chargesheet against former Chief Secretary V.K. Khanna, finding the proceedings were tainted by bias and malafide intent. Key Facts: Khanna, as Chief Secretary under the previous government, referred two CBI cases against senior officers in February 1997. Within 10 days of the new Chief Minister (Prakash Singh Badal) taking office, the incoming administration cancelled these notifications and subsequently charged Khanna with malafide conduct, gross procedural violations, and abuse of authority. Reasoning: The Court held that while administrative hastiness alone doesn't prove malafide conduct, the totality of circumstances—including the new government's swift reversal of Khanna's actions and a pre-emptive announcement that a judge would oversee his inquiry—demonstrated a predetermined bias against him lacking fair process. The Court affirmed that fairness and reasonableness are fact-dependent and bias must be evidenced by concrete facts, not mere allegations. This case analysis is maintained by casestatus.in based on publicly available court records.