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Wednesday, September 16, 2026 New Delhi Edition
Orissa High Court
High Courts

Lalit Kumar Dash v. State of Odisha & Ors. — Orissa High Court Directs Reconsideration of Judge's Adverse Service Record, Holds Its "Basis Washed Away" After Disciplinary Proceeding Was Quashed

The Orissa High Court has held that adverse remarks recorded in a judicial officer's Confidential Character Roll, based on charges in a disciplinary proceeding that was subsequently quashed, have "washed away" their foundation, and referred the matter to the Chief Justice for reconsideration.

Court
Orissa High Court
Case / Citation
W.P.(C) No. 10405 of 2024
Date of Decision
September 10, 2026
Bench
Justice Manash Ranjan Pathak and Justice Sibo Sankar Mishra
Parties
Lalit Kumar Dash v. State of Odisha & Ors.
Relevant Acts & Sections
Confidential Character Roll assessment norms, Odisha Judicial Service
Area of Law
High Courts
Headnotes
A 1997-batch Odisha Judicial Service officer who served as Registrar (Judicial) for only 42 days in 2021 received adverse CCR entries, marked "average" and "not trustworthy," based on charges in a disciplinary proceeding that the High Court itself later quashed in a separate petition.

Full Judgment Text

FACTS:

Lalit Kumar Dash, a 1997-batch Odisha Judicial Service officer, served as Registrar (Judicial) for only 42 days in 2021. He subsequently received adverse remarks in his annual Confidential Character Roll (CCR) — being marked "average" and described as "not trustworthy" — based on serious charges that were the subject of a disciplinary proceeding against him.

That disciplinary proceeding, along with the finding of guilt and major penalty imposed on Dash, was separately quashed by the Orissa High Court earlier in 2026. Dash then challenged the adverse CCR entries, arguing that since the disciplinary charges underlying them had been annulled, the entries could no longer stand, and separately that the entries violated the minimum four-month period ordinarily required for a CCR assessment.

COURT'S ANALYSIS:

A Division Bench of Justice Manash Ranjan Pathak and Justice Sibo Sankar Mishra found a strong case in Dash's favour, particularly given the subsequent quashing of the disciplinary proceeding that had formed the basis for the adverse entries.

The Bench observed: "the adverse materials which constituted the basis for recording the adverse entry in the petitioner's CCR having failed to withstand the scrutiny of law are washed away."

HOLDING:

The Orissa High Court allowed the petition to the extent of referring the matter to the Chief Justice for assessment of whether Dash's representations against the adverse CCR entries need to be reconsidered by the Full Court, in light of the disciplinary proceeding's annulment.

Source: LiveLaw, "'Basis Washed Away': Orissa High Court Directs Reconsideration Of Judge's Adverse Service Record," September 10, 2026.

Cases Cited & References

  1. 1. 2026 LiveLaw (Ori) 108
Nyay Vidhan
Court Judgments · 2 min read
Decided: September 10, 2026 Justice Manash Ranjan Pathak and Justice Sibo Sankar Mishra
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