Madhya Pradesh High Court Pulls Up Senior IAS Officer For Careless Order, Imposes Costs On State

The Madhya Pradesh High Court has come down heavily on administrative arbitrariness while setting aside a penalty and forfeiture order passed by the Collector, Chhindwara, in a case arising out of alleged illegal transportation of minerals, holding that the proceedings were conducted in a “mechanical and careless manner” without proper verification of ownership or liability.

A Division bench of Justice Vivek Rusia and Justice Pradeep Mittal, while allowing a writ petition filed by Sarang Raguwanshi, quashed the collector’s order dated January 27, 2025, which had directed forfeiture of a truck allegedly involved in illegal mining activities. The court also imposed costs of Rs. 50,000 on the State, directing that the amount be recovered from erring officers, thereby underscoring accountability within the administrative machinery.

The case arose after a truck was intercepted by the Revenue Officer in Chourai, District Chhindwara, on allegations of transporting minerals without requisite statutory permissions. A panchnama was prepared, and based on the statement of the driver present at the spot, the authorities proceeded against the petitioner, treating him as the owner of the vehicle. Subsequently, the Mining inspector submitted a report leading to issuance of a show-cause notice and eventual forfeiture order by the collector under Rule 23 of the M.P. Minerals (Illegal Excavation, Transportation and Storage) Rules, 2022.

Appearing for the petitioner, Advocate Shoeb Hasan Khan argued that the truck did not belong to his client and that the authorities had failed to verify the ownership despite readily available registration details. The petitioner had also placed on record documents showing that the vehicle was registered in the name of one Balveer Singh, with the registration valid until December 2027. Despite this, no effort was made by the Mining Officer to contact or record the statement of the registered owner.

On the other hand, Additional Advocate General Janhavi Pandit appeared for the State.

The High court found merit in the petitioner’s submissions, noting that the entire proceedings were initiated solely on the basis of the driver’s statement without any independent verification. The bench observed that “the petitioner has been wrongly treated as the owner of the vehicle, and the liability has been fastened upon him,” adding that such an approach reflected a lack of due diligence on part of the authorities.

In a strongly worded order, the court remarked that the collector, despite being a senior IAS officer, failed to examine crucial aspects of the case and “blindly accepted the report submitted by a subordinate mining officer.” It further noted that when quasi-judicial powers involving imposition of heavy penalties are exercised, authorities are expected to act in a judicial manner, ensuring fairness and proper application of mind.

The bench also expressed concern over the failure to take any action against the actual registered owner of the vehicle, observing that the authorities did not even attempt to verify the ownership details available in official records. Such lapses, the court indicated, not only undermine procedural fairness but also risk penalising individuals without any legal basis.

Quashing the impugned order, the court held it to be “unsustainable” in law and directed that the petitioner be compensated with costs. Importantly, the court directed the State to recover the amount from the officials responsible for the lapse, signalling a move towards fixing individual accountability in cases of administrative negligence.

Case Title: Sarang Raguwanshi v. The State of Madhya Pradesh and Others

Date of Order: March 13, 2026

Bench: Justice Vivek Rusia and Justice Pradeep Mittal