This Article is written by Adarsh Singh Thakur, a 3rd-year student, at Indore Institute of Law; and Upasana Sarkar, a student at Jogesh Chandra Chaudhuri Law College. This article deals with the doctrine of pleasure, which provides a detailed understanding of the relationship of the Government with its civil servants. It also discusses the scope, origin, and history of the doctrine of pleasure. It also gives a detailed analysis of the doctrine of pleasure in India and the UK, and a comparison is made between them.
It has been published by Rachit Garg.
Table of Contents
Civil Services were introduced in India during British rule therefore, their laws and regulations were also applied in India as per the needs of the country. After the independence of India, the civil services were provided Constitutional Status.
The laws of England still have a great influence on Indian laws. The doctrine of Pleasure is one of these concepts which has been introduced in India under British rule. Under this doctrine, the civil servants were regarded as servants of the crown and these civil servants served at their pleasure.
What is the meaning of the doctrine of pleasure?
As mentioned before, this doctrine originated in England. In England, the Crown is regarded as the Executive head and the civil services are part of the Executive. The doctrine of Pleasure means that the Crown has the power to terminate the services of a civil servant at any time they want without giving any notice of termination to the servant. Thus the civil servants work at the pleasure of the Crown which can remove them at any time. When the civil servants are removed from their service, they do not have the right to sue the Crown for wrongful termination and they also cannot ask for damages undergone due to wrongful termination. This doctrine is based on the concept of public policy and whenever the Crown feels that a civil servant should be removed from his office because keeping him will be against public policy, the Crown can remove such servant.
History and origin of the doctrine of pleasure
The doctrine of pleasure originated in England and came to India with the entry of the East India Company. At that time, India was under British rule. This doctrine owes its foundation to the Common Law. The British introduced this doctrine in India. It is derived from the Latin phrases ‘durante bene placito‘ and ‘durante bene placito regis‘. It means during good pleasure and during the good pleasure of the King, respectively. The King was considered to be the representative of God and so their decisions cannot be questioned by others. This doctrine was developed from the concept of the Crown, and it was thought that the king is a person who will always be infallible. It is believed that the servants of the Crown can hold their office at its pleasure and can be dismissed at any time the Crown wished. The tenure of the civil servants is not fixed, as they could be removed from their service without giving notice or stating the reasons for their termination. The civil servants were not allowed to ask about the reasons for their termination. Even the existence of a contract could not stop the Crown from dismissing the civil servants. Therefore, it shows that the relationship between the Crown and the civil servants is one-sided, as the Crown cannot be questioned by the servants for its decisions.
In India, during British rule, the Crown exercised this doctrine to remove any civil servant at any time they wanted. They worked only under the goodwill of the Crown. In spite of the East India Company being in power in India, the Crown had supreme authority to dismiss any civil servants whose appointments had been made by it in the East India Company. The Crown had the ultimate power in all sayings. The incorporation of this doctrine was first made in the Charter in 1833 and subsequently acknowledged in British India with its insertion in Section 240 of the Government of India Act, 1935. So it can be said that this doctrine emerged in India before its independence.
In the era of post-independence, English law still has a wide impact on the Indian legal system. So this doctrine is considered an important doctrine that was established at the time of British rule. It is one of the important theories that is still being followed in India. This notion states that the employees of the Government are similar to the civil servants of the Crown, who carry out their responsibilities at the whim of the employer. The employee has no right to question the employer in case of dismissal.
Scope of the doctrine of pleasure
The doctrine of pleasure discusses the tenure of civil servants under the Crown. In the case of Shenton v. Smith (1895), the Privy Council explained the doctrine of pleasure and upheld its importance. While explaining it, the Privy Council opined that in the absence of this doctrine, it would be difficult to remove those public servants from their service whose continuance in the office would have a detrimental effect on the State. In other words, it will be difficult to remove those civil servants if it becomes mandatory to show some sort of evidence of the offence to satisfy the court. This doctrine was again upheld in the case of Dunn v. Queen (1896), where it was observed that public servants have no fixed tenure. So they can be terminated from their service at any time on the Crown’s whim. In other words, it meant that the Crown could exercise its discretionary power to dismiss any public servant from employment. Therefore, it can be concluded that civil servants can hold office only at the pleasure of the Crown.
What is the position of doctrine of pleasure in India
The doctrine of pleasure is also followed in India. Since the President of India is the Executive Head of the Union and he enjoys the same position as the Crown enjoys in England, the President has been vested with the power to remove a civil servant at any time under this doctrine.
While this doctrine has been adopted in India it has not been blindly copied in the same manner as it is followed in England and there are some modifications which exist in India’s adoption of this doctrine from that of England. In India, Article 310 of the Indian Constitution embodies the provision for this doctrine.
According to Article 310, except for the provisions provided by the Constitution, a civil servant of the Union works at the pleasure of the President and a civil servant under a State works at the pleasure of the Governor of that State. This implies that the operation of the Doctrine of Pleasure can be limited by constitutional provisions. Under the constitution, the following are excluded from the operation of this doctrine:
- Judges of the Supreme Court;
- Judges of the High Courts;
- Chief Election Commissioner; and
- Comptroller and Auditor General of India.
Thus, this doctrine is not absolute and is subject to Constitutional provisions. The civil servants can also be excluded from the operation of this doctrine because they have been provided with some protection under Article 311 and thus this doctrine’s application can be limited to civil servants as well.
What are the constitutional safeguards for civil servants
The Civil servants have not only been provided with Constitutional status under Article 308 but they have also been granted some protection under Article 311. By providing the civil servants with these protections, the confidence of the public in the civil services is maintained and the civil servants are also provided with the assurance that they can honestly carry out their duties without any fear of unjust or unlawful removal from their office under this doctrine.
The following are the protections available to a civil servant under Article 311 of the Constitution:
1. No dismissal by subordinate authority
Under Clause 1 of Article 311, a civil servant can only be removed from his services by the authority who had appointed him or some other person who has the same authority or rank as the appointing authority. So, any person who is subordinate in authority to the appointing authority, cannot remove a civil servant and in case he does remove him, the removal will not be valid.
Illustration: A, a civil servant who was appointed by C. B who is a subordinate of C, removes A from his office. Here such a removal will not be valid because B did not have the same authority or rank as C (the appointing authority). But if D, who has the same authority as C, removes A then such removal will be valid under Clause 1 of Article 311.
2. The reasonable opportunity of being heard
Under Clause 2 of Article 311, the civil servants are provided with the right of being heard. This right embodies the principle of natural justice by giving a chance to the civil servant to prove his innocence.
As per this Clause, to remove a civil servant from his post the following steps should be followed:
- Holding an enquiry in the allegations made against the civil servant. This enquiry is known as departmental enquiry;
- Providing the accused civil servant with the information about what charges have been levelled against him;
- Providing such a civil servant with a reasonable chance of being heard in the case.
This protection is very important because under his Article the Civil servant is provided with a reasonable opportunity of being heard. While the clause mentions ‘reasonable opportunity’ it does not define its meaning. When no clarification is provided for the meaning of reasonable opportunity, it appears to be ambiguous protection because there is no method to determine whether a civil servant was provided with reasonable opportunity or not. Thus, the meaning of reasonable opportunity has been taken in the same meaning as the principles of natural justice are understood. Thus, a reasonable opportunity means that the accused is given a chance of presenting his side of the case in order to disprove the charges levelled against him and he should also have the chance to:
- Present his arguments before the body which is conducting the enquiry;
- Giving his statements as a witness;
- Listen to the statements of witnesses against him;
- Cross-examine the witnesses.
When such an opportunity is provided to a civil servant, the requirement of reasonable opportunity being afforded to him will be fulfilled.
Illustration: A is a civil servant and corruption charges have been levelled against him. A departmental enquiry is made to look into this matter and find out whether A is guilty or not. But A is not informed about any of the charges which are made against him and he has not been given a single opportunity to argue against these allegations and present evidence. The enquiry concludes that A is guilty without listening to A and as a result A is removed from his post. Such removal can be challenged by A in the Court and it will be held that the departmental enquiry was not valid and the removal of A cannot be deemed to be valid as it has violated the provisions of Article 311 Clause 2.
Who has the right to these protections
While these protections are provided to the people working for the Government, all the Government servants cannot avail of these protections. Thus, only certain people have the right to be protected under the provisions of Article 311.
The following people have the right to be protected under the provisions of Article 311:
The members of:
- Civil service of the Union;
- All India Service; and
- Civil service of any State.
- People who hold a civil post under the Union or any State.
By the words civil services, it has been made clear that the members of the Armed Forces are not part of the servants who are covered under the provisions in the Constitution, related to Civil Servants. In the case of Purshottam Lal Dhingra v. Union of India, it was held that the protection provided under Article 311 to civil servants includes permanently employed civil servants as well as temporarily employed civil servants.
What are the exceptions to the protection?
While protection has been provided under Article 311 of the Constitution to ensure that their interests are protected, these protections are also subject to some exceptions. When these exceptions arise in a case, the protection cannot be claimed by the concerned civil servant. The following are the exceptions:
- If the civil servant has been found guilty of a criminal offence, in such cases the protection under Article 311 cannot be availed for him and in such cases, he can be removed for misconduct without getting a chance of being heard.
Illustration: A is a civil servant who has been convicted by a court for a crime under IPC. In such case when the enquiry is made for charges against him, he may not be provided with the chance of being heard and he can be removed and such a removal will not amount to a violation of article 311. Also, he may also be removed without having an enquiry and it will also be a valid removal.
- In cases where the disciplinary charged with the task of looking into the allegations made against the civil servant, thinks that it is not practicable to hold an enquiry for the same, he has the power to not to hold such an enquiry. In the case of Union of India and Another vs Tulsiram Patel and Others on 11 July, 198, explained the scope of this exception. The Court observed that for determining the impracticability of holding the enquiry the point of view of a reasonable man has to be used. If a reasonable man who is in this situation thinks that holding such an enquiry is not practicable, then not holding such enquiry will not amount to a violation of Article 311.
- The last exception to the protection under Article 311 is the reasons of security of the State. This right is given to the President and the Governor as the case may be and whenever the President or the Governor is satisfied that it is not in the interest of the security of State to hold an enquiry, such an enquiry can be stopped from taking place. Here, actual threat to the security is not the focus of this exception but only the satisfaction of the President or Governor about the risk of threat to security is enough to invoke this exception. This exception appears to be a loophole against the protection to civil servants because satisfaction is a subjective concept and therefore what a person may consider being a threat might not be regarded to be the same by another person.
Thus, to remove this problem, the Government is required to inform the Court about the nature of the activity of the civil servant which is the basis for President’s or Governor’s satisfaction. If the Court finds the reason to be relevant, then the exception will be allowed but if the reason is not satisfactory or the government fails to disclose this information to the court, the validity of the removal of the civil servant will not be upheld by the court and this exception will not be applied in such a case.
Restrictions imposed upon the doctrine of pleasure
The doctrine of pleasure must be applied while keeping in mind the following restrictions-
- The contract that has been made between the civil servants and the government may be enforceable.
- The Indian Constitution guarantees the citizens of India certain fundamental rights. Article 14, Article 15, and Article 16 of the Constitution of India impose certain restrictions on the free and unfair use of the doctrine of pleasure. This doctrine of pleasure cannot be used without sufficient cause. Article 14 states that the use of any principles or doctrines must be done on reasonable grounds. It prohibits the exercise of a doctrine arbitrarily. Like Article 14, Article 15 also prevents the arbitrary exercise of this doctrine of pleasure. This Article has imposed certain restrictions before their termination from services on the grounds of religion, race, caste, sex, or place of birth. The Constitution also states that all citizens must be treated equally without any unreasonable discrimination under Article 16.
- The Indian Constitution lays down provisions to restrict the application of the doctrine of pleasure to the tenure of the High Courts and Supreme Court judges, the Chief Election Commissioner, the Comptroller and Auditor-General of India, and the Chairman and Members of the Public Service Commission.
Termination of service amounting to the punishment of dismissal
The two main circumstances under which the termination of service will amount to punishment of removal are as follows-
- Under certain circumstances, where the public servant is terminated from his service, it might amount to a punishment of dismissal. One such situation can be when a person has the right to hold the post but is terminated from his service. In that situation, his termination itself amounts to dismissal, as he had the right to hold his office but could not as he was removed from it. Although if that public servant has no right to hold a certain post and he is removed from it or transferred to a lower post, then there would not be any deprivation of the person’s right. So it means that the person has not received any punishment.
- Another situation is when a person works temporarily for a particular post but has no right to hold that post. If, in that situation, he is removed or dismissed from his post, subjecting him to certain negative outcomes, then it constitutes punishment.
Supreme Court’s decision on the discretionary power of the Governor in relation to the doctrine of pleasure
In the case of Shamsher Singh v. State of Punjab (1974), the Supreme Court upheld the provision that the President is usually bound to follow the advice of the Council of Ministers as he is the nominal head of the State. Being the executive head, he is not empowered to do anything against or without the suggestions of the Council of Ministers. He is not permitted to go against their decision if the majority of the Ministers of the Parliament approve it. Therefore, it can be seen that the positions of the Governor and the President are similar, as both of them are the titular heads without any actual power to take decisions regarding any matters. So this principle is also applicable in the case of the Governor of a State, as the Union Minister also holds the office “during the pleasure of the President”, which is stated in Article 75(2) of the Indian Constitution.
In the case of Nabam Rebia v. Deputy Speaker And Ors (2016), the Supreme Court of India upheld the opinion of B. R. Ambedkar, who observed that the Governor cannot discharge any duties on his own. He is always dependent on the advice of the Cabinet Ministers. He has no right to exercise any power independently. He has not been given any function under the Constitution of India to do any act himself without the instructions of the Ministers.
The Indian legal system is in the hands of the Judiciary, which is an independent body. The legislature and the executive are those bodies that are interdependent on each other, unlike the judiciary. The Judiciary is kept independent for fairness and justice so that it does not get influenced by anyone while rendering justice. The doctrine of pleasure has no application in the Indian Judicial System. It means that judges of the High Courts and the Supreme Court are exempt from the application of the doctrine of pleasure. In other words, the judges of the Courts cannot be removed using this doctrine. Not only the judges of the courts but also other categories of people such as the Indian Audits and Accounts Department, defense personnel, Public Sector undertakings, and a few others are exempt from this doctrine as they also cannot be removed from their offices under this doctrine of pleasure.
In the case of Union of India v. Balbir Singh (2017), the Supreme Court stated that when a public servant is dismissed from his office, the reasons or grounds for his removal will be inspected by the court. After examining the reasons, if the court is well satisfied with them their termination will not be reversed. But if the ground seems to be irrelevant for which he was dismissed as it does not affect the security of the State, then the ground for the public servant’s termination will be considered invalid.
What is the role of Indian judiciary on the doctrine of pleasure
Judiciary plays a very important role in India by performing its function as the interpreter of laws. While the doctrine of pleasure has been adopted from the English Law, Judiciary has through various cases, provided its judgments regarding the applicability of this doctrine in India.
In the case of State of Bihar v. Abdul Majid, the rule regarding the maintainability of a claim by the civil servant regarding arrears for salary was decided by the Supreme Court. In England, the rule was that a servant could not sue the Crown for arrears of salary. The same was argued in this case. A sub-inspector had been removed from his service on the ground of cowardice and was later re-hired. He filed a suit for recovering the arrears of his salary but the Government contended that he cannot do so under the rule followed in the doctrine of pleasure. The Supreme Court held that this rule would not apply in India and thus the sub-inspector had the right to claim the arrears of his salary.
Similarly, the Court also made a judgment regarding another important provision of the doctrine of pleasure. In the case of Union of India v. Balbir Singh, it was held that the Court has the power to examine the satisfaction of the President or the Governor as the case may be. If the Court finds that the satisfaction is based on such grounds which have no relation to the security of the State then, the Court can hold such a satisfaction to be based on irrelevant and extraneous grounds and the dismissal of a civil servant can be held invalid.
A detailed analysis of the doctrine of pleasure in India and UK
As discussed earlier, the Indian legal system has borrowed this doctrine of pleasure from England and developed it in accordance with the Indian legal structure. In short, this doctrine means the persons, who are the civil servants, work at the will and pleasure of the Crown with a risk of being terminated at any time without any prior notice or reason. At the time of their termination, they are neither given any damages nor the salary for the duration for which they were appointed to the service. In other words, the doctrine of pleasure means ‘tenure at pleasure’ of the Crown.
Doctrine of pleasure in the UK
The concept of the doctrine of pleasure is previously discussed in this article, where it is mentioned that it was developed in the United Kingdom and discusses the Crown’s right to remove or dismiss a public employee at any time, whenever they want to do so. In the UK, this doctrine is established on the concept of the sovereign right of the Crown, where the King is considered to be the representative of God and has the ultimate power, and is not capable of doing anything wrong. His judgments cannot be questioned, as he is considered superior and is devoid of making any mistakes. So it can be concluded that the relationship of the Crown with its civil servants is unilateral in nature.
The nature of this doctrine also seems absolute in the UK, as the civil servants remain in their offices under the absolute authority of the Crown and can be dismissed from their service at the discretion of the Crown. In short, they hold office at the pleasure of the Crown. His decisions are final in all appointments as well as the removal of civil servants. If they are being hired on a contractual basis, then the absolute power to keep them or remove them from their service is also in the hands of the Crown. If they are dismissed from their offices, they will neither get any compensation for their termination nor have any right to challenge the Crown’s or official’s decision to appoint them. Therefore, making a contract at the time of their appointment or recruitment into a service also cannot protect the civil servants from getting dismissed by the Crown. The contract has no value in the eyes of the law.
Doctrine of pleasure in India
The doctrine of pleasure in India is governed by Article 310 and Article 311 of the Indian Constitution, as mentioned in this article in detail. It lays down the provisions relating to the offices of the civil and defense servants of the Union and States, which they can hold only at the pleasure of the President and the Governor. In India, the doctrine of pleasure is not absolute like that of the UK. In India, the Constitution has laid down certain methods to punish those who are involved in corruption or for whom corruption is increasing in society. Therefore, the Judiciary is always kept independent from the legislature and executive. So the judges of the High Courts and Supreme Court are not governed by this doctrine. This helps the judges pass a fair judgement without any kind of influence. This doctrine is also not applied to other civil servants such as the Chief Election Commission, members of the Public Service Commission, and the Auditor General.
The notion that the King is the ultimate head who is devoid of doing anything wrong is not acceptable in India. While the rules of the doctrine of pleasure are laid down in Article 309, the limitations are given in Article 311 which restricts unreasonable removal of public servants. In short, Article 311 functions like a proviso to Article 310. There are certain conditions inserted for the protection of the civil servants from dismissal by a subordinate authority. They are given a reasonable opportunity to be heard in the event of their termination from service. Therefore, it instills faith among the people in the country’s civil service department. The public servants are also guaranteed certain rights so that they can perform their duties without any unreasonable fear of being removed from their office under the doctrine of pleasure. So it can be concluded that the relationship of the State with its civil servants is not unilateral in nature, like in the United Kingdom, as they can sue the State if they think the dismissal from their service is done on some unreasonable ground.
Differences between India and the UK regarding the doctrine of pleasure in a tabular format
The doctrine of pleasure in the UK can be applied to all civil servants, irrespective of any exceptions.
The doctrine of pleasure in India can be applied to most of the civil servants, with a few exceptions.
If the civil servants are appointed based on any contract or on a contractual basis, then the Crown can also terminate a civil servant without giving notice or a reason.
If the civil servants are appointed on a contractual basis, then the State cannot terminate a civil servant without a reasonable ground, and the contract will be enforceable in a court of law.
Any actions taken against the civil servants by the Crown cannot be challenged in a court of law.
If the State takes an action against a civil servant that seems wrong, it can be challenged in a court of law.
The relationship of the Crown with its civil servants is unilateral and absolute in nature.
The relationship of the State with its civil servants is neither unilateral nor absolute in nature.
Recent judicial pronouncements
- In the case of Union Of India And Others v. Major S.P. Sharma And Others (2014), many of the officers suspected of having committed the crime of espionage were from the neighbouring country, Pakistan. The espionage activities took place from 1975 to 1985. Therefore, when the activities were found, it seemed to be a national threat, and the security of the nation was in question. For this reason, the Court Martial tried these officers to find out whether they were actually a part of the espionage activity or not. They were tried under Section 18 of the Army Act, 1950, to ascertain whether the safety of the nation was under threat or not. After the completion of the proceedings, they were terminated from their office. After that, when the aggrieved parties were dismissed from their offices, they appealed to the Delhi High Court by filing a writ petition. But that special leave petition was also dismissed by the Court. So they had no other option other than finally moving to the Supreme Court against the dismissal of the petition by the Delhi High Court. They argued that the grounds of alleged misconduct in espionage had not been tried by a Court Martial. Not only that, even when they submitted an appeal petition, the Delhi High Court dismissed it without giving them an opportunity to be heard. In the opinion of the Supreme Court, the court can only review whether the actions for termination of service were taken on the basis of relevant evidence or not. Other than that, they cannot determine what grounds would be sufficient to do so. It was further stated that no justification is needed to be given for using the doctrine of pleasure The conclusion drawn by the Court was that no court is permitted to draw a different judgement in a case based on evidence that has been recorded. The right of the President to appoint a person to hold his office at his pleasure, whose service can be terminated by the President at any time without stating the reason for doing so, was upheld by the Supreme Court of India in this case. For terminating a public servant from his post, the authority will not be held accountable for such an act.
- In the case of Sunny K. George v. State Of Kerala (2016), the members of the Syndicate of Mahatma Gandhi University submitted the writ petition. They were being nominated by the Government in accordance with the provisions of Section 21 of the Mahatma Gandhi University Act, 2010, under a notification. The petitioners contended that the nominations were changed afterwards through another notification. At that time, the petitioners names were removed and replaced by a new set of people by intimidating the Registrar of the University, which is unfair in the eyes of the law. The petitioners also mentioned that the tenure after the appointment is four years for the Syndicate’s members. So any notification that was issued thereafter should be considered illegal and arbitrary. They also stated that the Government has no right to act arbitrarily simply because the earlier government is no longer in power due to the formation of a new government. The Kerala High Court observed that the doctrine of pleasure does not give an unfettered right to act in an arbitrary manner. They have no power to withdraw their pleasure at their own discretion without appropriate reasons. It was also upheld that the removal or dismissal of public servants from their offices can be done at the authority’s pleasure without stating the reasons for their removal from the office, where the authority is not required to give a notice or reason for doing so. But this does not mean that they can exercise that power arbitrarily at any time, whenever they want to do so, without any valid reasons or grounds for doing so. Therefore, the Court’s ultimate conclusion was that the doctrine of pleasure does not give power to any authority to act in an arbitrary, whimsical, or capricious manner.
- In the case of Rajendra Prasad Baudh v. State Of U.P. Thru Secy. Housing (2016), the petitioner filed a writ petition in the Allahabad High Court requesting the Court to dismiss the nomination order that has been passed by the State Government by issuing certiorari. The petition was submitted by a person who is a Buddhist by religion. He raised arguments against the nomination for the post of Vice President of the International Bauddh Research Institute in Uttar Pradesh because the name of the person listed for it was neither a Buddhist nor a follower of Buddhism. He was Hindu by religion who was nominated. So, it can be justly concluded that the decision taken by the State Government was unfair and arbitrary. This nomination was done only to serve the political interests and nothing else. The petitioner prayed for the cancellation of the nomination for the post of Vice President, as the real purpose would not be served if he were appointed. In the view of the Court, the doctrine of pleasure in a democratic country is very different from a feudal set-up. The Court stated that a democratic country does not have an unfettered right to do anything as it pleases, like that of the Crown. They are not permitted to act arbitrarily, capriciously, or whimsically. They can only use this doctrine of pleasure in a reasonable manner and only for the welfare of the public. In other words, it can be concluded that the right to remove a public servant from his office is guaranteed to authority under this doctrine of pleasure, and he can ‘at pleasure’ do that without stating reason or giving notice, but there are certain restrictions imposed upon the authority. The authority does not have the right to dismiss a public servant at its whim. Otherwise, the morality of this doctrine would be lost.
While the doctrine of pleasure has been adopted from the British legal system, it has been modified to suit Indian context as per prevailing social structure in India. The judiciary has played a key role in balancing the arbitrary aspects of this doctrine by their power of judicial review.
While England has a Monarch as the Executive head, India elects its Executive head through elections. So, the principle ‘the King can do no wrong’ is not suitable to the Indian scenario. Despite the judicial intervention, the exceptions to the protection can still be misused. Therefore instead of reviewing each and every instance of arbitrariness, it would be better if certain guidelines are provided which have to be followed while availing these exceptions. If these guidelines are not followed the dismissal can be held invalid which will also provide speedy redressal to the aggrieved party.
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