4 min readNew DelhiJul 21, 2026 01:14 PM IST
The Allahabad High Court recently struck down an adverse Annual Confidential Report (ACR) entry of “doubtful integrity” made against a judicial officer, observing that the material on record did not substantiate such a finding.
A division bench of Justices Arindam Sinha and Satya Veer Singh allowed the plea filed by an additional civil judge (senior division) who had challenged the adverse remarks recorded in her ACR for the period between April 1, 2019 and March 31, 2020 while she was posted in Ghaziabad.
“The civil Court presided over by petitioner is the court of first instance in the outlying area of the district. Judgment/orders given by her are amenable to correction in appeal/revision. However, since the entries were there, the District Judge made the remarks. They relate to the merits of the matter discussed. They have nothing to do with integrity of petitioner,” the order dated July 10 read.
The judge had moved the high court seeking to expunge an adverse remark made by her senior officer in the ACR. The report had described her integrity as “doubtful”, citing oral complaints by advocates, and stated that she did not command a good reputation as several members of the Bar had complained about her behaviour and rudeness.
The judge, however, argued that the district judge had no basis to record such remarks and that her representations against the adverse entry had not been properly considered. She also challenged the communications rejecting those representations.
Justices Arindam Sinha and Satya Veer Singh noted that the adverse remarks in question stemmed from two injunction-related matters.
The counsel appearing on behalf of the high court administration said that the district judge’s remark was based on the complaint letters received from the Bar.
Negligence not ‘doubtful integrity’
The bench referred to the Supreme Court’s earlier remarks which explained that integrity denotes honesty, uprightness and freedom from corrupting influence, and that negligence or unintentional acts cannot amount to “doubtful integrity”. The judges also relied on the dictionary meaning of integrity as ‘character of uncorrupted virtue’ and said no allegation in that regard was established.
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The court noted that the portfolio judge’s remarks were primarily based on the district judge’s feedback and subsequent allegations of insubordination, without any indication that the petitioner herself had been heard before the adverse entry was affirmed. A portfolio judge is a senior judicial officer who has administrative and supervisory responsibility.
The bench noted that the adverse remarks in question stemmed from two injunction-related matters. In one, she was criticised for rejecting an injunction plea connected to a sale deed. In another, she had observed that while the land belonged to the plaintiff, the building on it did not.
The ACR evaluated whether her interim orders were passed for valid reasons and whether her judgments were legally sound, well-reasoned and expressed in clear language, it said, adding that since she was serving as a trial judge, her orders were subject to appeal or revision. The court said the remarks related only to the merits of her judicial decisions and had nothing to do with her integrity.
Setting aside the adverse entry, the high court ruled that the remarks branding the petitioner as having “doubtful integrity” could not be sustained. It also noted that her service record contained no similar remarks either before or after the relevant period, making her eligible for relief.
