New Delhi, May 21, 2025: The Supreme Court on Wednesday struck down a Madhya Pradesh government order that allowed Indian Administrative Service (IAS) officers to review the performance appraisal reports of Indian Forest Service (IFS) officers, calling the directive “contemptuous” and a clear violation of earlier court rulings.
A bench comprising Chief Justice BR Gavai and Justice Augustine George Masih ruled that the state’s June 29, 2024 order was contrary to the apex court’s decision dated September 22, 2000. That judgment had laid down that performance assessments of IFS officers up to the rank of Additional Principal Chief Conservator of Forests must be done by their immediate superiors within the forest department itself.
The only exception, the 2000 verdict stated, was for the Principal Chief Conservator of Forests, who may be reviewed by a non-forest service officer, as there is no higher-ranking IFS officer.
Madhya Pradesh had continued the practice of allowing IAS officers—including district collectors and higher-ranking administrative officials—to record annual confidential reports (ACRs) of IFS officers, despite the Supreme Court’s explicit directions.
“Such a government order is not only in breach of this Court’s decision but is rather contemptuous, issued without even seeking any clarification or modification from this Court,” the bench observed in its judgment.
While acknowledging that most states had complied with the 2000 ruling, the court expressed concern that Madhya Pradesh remained an exception. Though the court noted it had grounds to initiate contempt proceedings, it chose restraint. “We refrain from doing so,” the bench said, instead quashing the order and instructing the Madhya Pradesh government to amend its rules within a month in strict adherence to the court’s earlier directive.
The judgment clarified that states could, if required, ask IAS officers such as collectors and commissioners to provide input on the implementation of developmental works involving IFS officers. However, such feedback must be submitted separately and evaluated by a superior IFS officer, not incorporated directly into the appraisal process.
The court also noted that the now-quashed order required forest officials, such as conservators or chief conservators, to seek performance notes from district collectors before preparing appraisals of Divisional Forest Officers. This, it said, further underlined the procedural flaws.
The Department of Personnel and Training had earlier clarified in 2004 that the Supreme Court’s 2000 order applied specifically to IFS officers posted within the forest department and not to those serving outside it.
With this ruling, the court reaffirmed the autonomy of the Indian Forest Service in managing its internal assessments and upheld the principle that performance reviews should be handled within the same cadre to maintain administrative discipline and functional integrity.
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