State of Madhya Pradesh & Ors. Vs Rajkumar Yadav (Supreme Court of India)
Conclusion: An acquittal based on the benefit of doubt did not confer upon a candidate an automatic right to appointment in public service. Mere involvement of a person in an alleged offence or in the act of moral turpitude may become sufficient enough to apply it as debilitating factor for such candidate to be offered employment. Antecedents of a candidate play an important role in the decision-making process by the screening committee. This dictum would operate with greater rigour when it comes to the recruitment and appointment to the disciplined force like police.
Held: Respondent applied for appointment as Constable (Driver) in the police force. During character verification, it was found that he had been prosecuted for serious offences involving moral turpitude (kidnapping and rape), though later acquitted by the trial court on benefit of doubt. The Screening Committee rejected his candidature treating him unsuitable. The Single Judge upheld the rejection. However, the Division Bench of the High Court set aside the decision, treated the acquittal as “honourable” and directed reconsideration. The State challenged the same. The issues arose for consideration was whether acquittal on benefit of doubt amounted to “honourable acquittal”; whether such acquittal entitled a candidate to appointment in police service; scope of judicial review over decisions of screening committees in recruitment to disciplined forces. It was held that acquittal on benefit of doubt was not an honourable acquittal. An honourable acquittal arose only when the court recorded a clear finding that the accused was completely innocent. Where acquittal was based on insufficiency of evidence, it remained a technical acquittal. The Court reiterated that acquittal did not automatically entitle a candidate to appointment, especially in disciplined forces like police. The employer was entitled to consider nature of offence, antecedents, and character while assessing suitability. Even involvement in serious offences involving moral turpitude could be a valid ground to reject candidature, notwithstanding acquittal. The Screening Committee had wide discretion to assess suitability, and its decision should not be interfered with unless arbitrary, mala fide, or perverse. The High Court erred in substituting its view and treating the acquittal as honourable, thereby encroaching upon the domain of the employer. Accordingly, the rejection of candidature by the Screening Committee was justified.






