Vulgar Messages by Married Uniformed Officer to Woman Amount to ‘Unbecoming Conduct’: Delhi HC

The Delhi High Court has held that a member of a uniformed force who is already married has no business to indulge in a relationship with another woman and send vulgar messages, observing that such conduct is “definitely unbecoming of an officer of a Uniform Force.”

In a detailed 18-page judgment, a Bench of Justice Subramonium Prasad and Justice Vimal Kumar Yadav dismissed the plea of CISF Sub-Inspector (Executive), who had challenged a disciplinary order reducing his pay by one stage and a subsequent revisional order upholding that punishment.

The petitioner had approached the High Court challenging the September 29, 2016 order of the Deputy Inspector General, CISF, North Zone-II, which awarded him the penalty of reduction in pay from Rs 38,700 to Rs 37,600 for two years. The order also directed that he would not earn increments during this period and that his future increments would stand postponed.

His revision petition before the Director General, CISF, was also rejected. The Revisional Authority observed that his claims were “vague, unspecific and unsubstantial,” and that the departmental inquiry had been conducted in accordance with law. It held that the petitioner’s defence lacked merit and that the allegation of denial of witness statements could not be sustained as the preliminary enquiry report had not been relied upon during the proceedings.

“The Revisional Authority has carefully gone through the enquiry proceedings and the submissions given by the petitioner,” the Bench noted, adding that “the petitioner being married, was under moral obligation not to indulge in a relationship with another lady and send vulgar messages.”

The disciplinary action stemmed from a complaint by a lady Sub-Inspector posted in the same CISF unit, alleging that Hussain had sexually harassed her by sending vulgar WhatsApp messages such as “darling” and “I love you,” and making inappropriate phone calls. She also alleged that he had once entered her house “with malafide intentions.”

Following the complaint, a departmental inquiry was conducted under Rule 36 of the CISF Rules, 2001. The inquiry officer examined witnesses, including the complainant’s parents, and relied on WhatsApp messages and call recordings as evidence.

The Enquiry Authority, after reviewing the material, concluded that Hussain was guilty of harassing his colleague, holding that the nature of the messages was such that they could not be accepted from a member of a uniformed force.

While dismissing the petition, the Bench observed,“The petitioner being a member of a Uniform Service was already married and had no business to indulge in a relationship with another lady and send vulgar messages. This conduct is definitely unbecoming of an officer of a Uniform Force.”

Court further remarked,“The punishment given to the petitioner is commensurate with the misconduct. Rather, this Court is of the opinion that the petitioner has been left very lightly.”

Hussain had argued that the complaint was “false and mala fide,” claiming that he and the complainant were in a mutual relationship and that she had filed the complaint after a quarrel. He also contended that the messages were exchanged with her consent.

The Court rejected these contentions, holding that both the inquiry and revisional orders were detailed, reasoned, and based on evidence.

“Applying the law laid down in a catena of judgments, this Court does not find any infirmity in the enquiry proceedings,” the Bench said. “The principles of natural justice have been followed.”

With these findings, the Court dismissed the writ petition, upholding the disciplinary punishment imposed on the CISF officer. 

Case Title: Khaja Hussain vs Director General, Central Industrial Security Force & Ors

Date of Decision: September 22, 2025

Bench: Justice Subramonium Prasad and Justice Vimal Kumar Yadav