CAT Refuses to Quash Disciplinary Proceedings Against Retired Karnataka DGP K. Ramachandra Rao Over Obscene Video

The Central Administrative Tribunal (CAT), Bangalore Bench has dismissed a plea by retired Karnataka Director General of Police Dr. K. Ramachandra Rao seeking to quash disciplinary proceedings initiated against him over an alleged obscene video showing him with a woman while in police uniform.

A Bench of Justice S. Sujatha and Dr. Sanjiv Kumar dismissed Rao’s Original Application on August 27, 2026, holding that there was no ground to interfere with the charge memo at this stage.

The Tribunal clarified that it could not examine the truth or merits of the allegations at the charge-memo stage, as that was a matter for the departmental inquiry.

Allegations Against Former DGP

The proceedings followed the circulation of a video on news channels and media platforms on January 19, 2026, allegedly showing Rao behaving in an obscene manner with a woman while wearing his police uniform.

Rao was then serving as Director General of Police, Directorate of Civil Rights Enforcement. He was placed under suspension with immediate effect pending inquiry, with the State citing alleged conduct unbecoming of a government servant and embarrassment caused to the Government.

A four-member committee subsequently conducted a preliminary inquiry. Its March 16 report stated that the material indicated that Rao had engaged in inappropriate conduct with a woman while on duty and in uniform in his office during his tenure as IGP, Northern Range, Belagavi, allegedly violating Rule 3(1) of the All India Services (Conduct) Rules, 1968.

The State issued Articles of Charge on March 18, 2026. The charge alleged that Rao, as an All India Services officer, was required to maintain “high ethical standards, integrity and good behavior”, but had allegedly committed gross misconduct, misused his official position and caused embarrassment to the Government and department.

Rao’s challenge

Rao denied the allegations and argued that the disciplinary proceedings were liable to be quashed.

He contended that the authorities had acted with a predetermined mind because the communication directing the preliminary inquiry also referred to preparation of Articles of Charge.

He also argued that the alleged conduct dated back to his 2016-17 tenure as IGP, Northern Range, Belagavi, while the proceedings were initiated in 2026.

Among other grounds, he pointed out that no complaint had been lodged by the woman allegedly appearing in the video and challenged the validity and approval of the charges.

A further argument was that although the Home Minister and Chief Minister had approved the charge memorandum, there was no separate approval for initiation of the disciplinary proceedings.

CAT Rejects Approval Argument

The Tribunal rejected the contention that a separate initial approval for initiation was necessary.

Relying on the Supreme Court’s subsequent decision in State of Jharkhand v. Rukma Kesh Mishra, the CAT held that the disciplinary authority was not required to give a separate approval merely for initiating disciplinary proceedings when the charge memo itself had been approved.

The original government files showed approval of the charge memo by the Home Minister and Chief Minister, the Tribunal noted.

The CAT observed that once the chargesheets themselves had been approved, the fact that there may not have been, on the file, any independent approval for the proposal to initiate disciplinary proceedings, could not make any difference in law.

No Predetermination Or Delay

The Tribunal also rejected Rao’s claim that the authorities had predetermined the outcome.

It held that the direction to prepare Articles of Charge was consequential to the preliminary inquiry and did not establish that the committee had been instructed to find the officer guilty.

The committee was required to frame charges only if the material justified them, and it subsequently found a prima facie case.

On the question of delay, the CAT observed that although the alleged conduct related to Rao’s tenure in 2016-17, the matter came to light only when the video surfaced in January 2026. It therefore found no basis to invoke delay or laches and noted that the State had acted swiftly after the allegations emerged.

‘Government Office Is Like A Temple’

The Tribunal made strong observations about the standards expected from senior police officers. It remarked: "A police officer is expected to protect lives and property, enforce laws, maintain public order, discipline, building trust with citizens with clean criminal record. A police uniform symbolises state authority, maintains order, provides instant identification and safety for officers".

It added that if the officers of high ranking on whom public trust is reposed is alleged of behaving in an obscene manner in uniform with a woman, the same certainly offends the public feelings at large, women in particular.

The Tribunal further observed: "Government office is like a temple where high ethical standards, integrity and good behaviour are expected. Officer in the high rank is the role model to his subordinate officers.”

The Tribunal then turned to the standards expected from public officials and the significance of the office held by Rao. Referring to “Satyameva Jayate”, India’s national motto, the CAT observed that it represents the moral and ethical foundation of Indian democracy and public life.

The Tribunal noted that the motto is inscribed at the base of the national emblem and appears in government offices as a reminder of the importance of maintaining high ethical standards.

At the same time, the CAT stressed that these observations did not amount to a finding that Rao was guilty.

It held that the Tribunal could not determine the truth, correctness or merits of the charges at the charge-memo stage. Those questions would have to be examined by the inquiry and disciplinary authorities.

The Tribunal also held that the absence of a complaint from the woman allegedly appearing in the video did not, by itself, invalidate the charge memo. Likewise, her non-inclusion in the witness list was not sufficient to quash the proceedings.

‘Challenge To Charge Memo Is Premature’

Reiterating the settled principle that courts should ordinarily not interfere with departmental charge sheets at the threshold, the CAT observed that a charge memo is not itself a punishment.

It held that interference would ordinarily be justified only where the proceedings are wholly without jurisdiction or otherwise legally unsustainable.

The Tribunal observed: "Issuing of a charge memo is not imposing of any penalty order. As such, challenge to the charge memo is premature."

Finding no merit in Rao’s challenge, the CAT dismissed the Original Application.

Case Title: Dr. K. Ramachandra Rao v The State of Karnataka And Ors

Date of Order: August 27, 2026

Bench: Justice S. Sujatha, Member (J) and Dr. Sanjiv Kumar, Member (A)

Tags: