Summary and Analysis of In Re: Mepung Tadar Bage, Member, Arunachal Pradesh Public Service Commission 2025 INSC 1047

1. Heading of the Judgment

Supreme Court of India – In Re: Reference under Article 317(1) of the Constitution of India regarding Shri Mepung Tadar Bage, Member, Arunachal Pradesh Public Service Commission (APPSC).

2. Relevant Laws and Sections 

• Article 317(1), Constitution of India – deals with removal of a Chairman or Member of a State Public Service Commission by the President on the ground of misbehavior, after a Supreme Court inquiry.

• Article 315 & 316 – structure, appointment, and tenure of State PSC members.

• Service Conduct Rules & Examination Guidelines – referred for evaluation of charges related to recruitment/examination processes.

3. Basic Judgment Details

• Inquiry initiated: Allegations of irregularities and misconduct by Shri Mepung Tadar Bage in the functioning of APPSC.

• Bench: Supreme Court Judges (Inquiry Bench under Article 317).

• Core issue: Whether the proven acts of the APPSC Member amount to “misbehavior” warranting removal from office.

4. Explanation of the Judgment 

(i) Background of Allegations

Complaints were raised that Shri Bage was involved in serious irregularities in the conduct of recruitment examinations, including favoritism, malpractice in answer script evaluation, and violation of established examination procedures.

(ii) Inquiry by the Supreme Court

• The President referred the matter to the Supreme Court.

• The Court examined the charges, evidence, and witness testimonies.

• Multiple irregularities were substantiated, including tampering of marks, misuse of position, and lack of transparency in recruitment.

(iii) Findings of the Court

• The Court held that the conduct of Shri Bage compromised the integrity of the APPSC.

• His actions were inconsistent with the constitutional trust placed in a PSC Member.

• The Court emphasized that PSCs must maintain absolute fairness, impartiality, and credibility in recruitment.

(iv) Application of Article 317

• The Court concluded that the charges amounted to “misbehavior” under Article 317(1).

• It was observed that even a single proven act that undermines public confidence in a constitutional body like PSC is sufficient for removal.

Conclusion

• The Supreme Court recommended the removal of Shri Mepung Tadar Bage from the office of Member, APPSC.

• It stressed that PSC members must act with highest integrity, as they are trustees of public faith.

• The decision reinforced the principle that malpractice in recruitment shakes the foundation of meritocracy and cannot be tolerated.