‘Moral Lapse’: Allahabad HC Says Dismissal Over Teacher-Student Relationship Excessive

The Allahabad High Court recently held that while a lecturer at Motilal Nehru National Institute of Technology committed misconduct by entering into a consensual relationship with a student, the penalty of dismissal from service with disqualification imposed on him was shockingly disproportionate and required reconsideration by the disciplinary authority.

Justice Saurabh Shyam Shamshery, disposing of a writ petition filed by Rajesh Singh, interfered with the punishment imposed by the institute but did not disturb the finding of misconduct.

Court remitted the matter to the disciplinary authority only on the limited issue of quantum of punishment, directing it to pass a fresh order in light of the court’s observations.

Singh was appointed as a Lecturer

in the Computer Science and Engineering department of Motilal Nehru National Institute of Technology in March 1999. In January 2003, a former woman student of the institute lodged a complaint before the Director alleging that Singh had entered into a physical relationship with her during her student years. While she initially described one incident as non-consensual, she also stated that the relationship later became consensual and continued for nearly three years after she left the institute. No criminal complaint or FIR was ever lodged.

An internal five-member committee constituted by the institute did not return any conclusive finding on sexual assault and noted that the relationship continued even after the student ceased to be enrolled. Singh was subsequently placed under suspension, and the institute later appointed a One-Man Inquiry Commission headed by a former judge of the High Court.

The One-Man Commission concluded that Singh had committed gross misconduct by showing special favour to the student and engaging in a relationship that was incompatible with the ethical standards expected of a teacher. Emphasising the sanctity of the teacher-student relationship and societal expectations from educators, the Commission recommended termination from service. Acting on this report, the Board of Governors dismissed Singh from service in February 2006 with disqualification from future employment.

Before the High Court, Singh challenged the dismissal primarily on procedural grounds, arguing that the institute had failed to follow its own disciplinary rules. He pointed out that no formal charge-sheet was issued, no inquiry officer or presenting officer was appointed, and no opportunity was given to cross-examine witnesses, despite a detailed procedure being prescribed under the institute’s service regulations.

Court acknowledged that the disciplinary proceedings were not conducted strictly in accordance with the prescribed procedure. However, it held that Singh had not suffered prejudice on facts, as he had substantially admitted the relationship, which formed the basis of the misconduct finding.

Court observed that even if a full-fledged departmental inquiry had been conducted, the conclusion on misconduct was unlikely to have been different.

At the same time, court closely examined whether the nature of the misconduct justified the extreme penalty imposed. It noted that the relationship was admittedly consensual, that it continued long after the complainant left the institute, and that the complaint was lodged several years later, following the breakdown of the relationship.

Court also observed that the case did not amount to sexual harassment and that no other allegations were made against Singh during his service.

“In case petitioner got married with complainant after their relationship of three years, possibly no complaint was filed,” court said.

Holding that the punishment of dismissal with disqualification rested solely on considerations of morality, court found it to be disproportionate in the facts of the case. It clarified that while a teacher is undoubtedly expected to maintain high moral standards, punishment must bear a rational nexus to the nature and gravity of the misconduct.

Accordingly, the High Court interfered only with the quantum of punishment and remitted the matter to the disciplinary authority to reconsider and impose an appropriate penalty in accordance with law. The writ petition was disposed of with these directions.