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Madhya Pradesh High Court stays suspension of teacher who mimicked PM Modi over LPG prices

The Court said that an employee cannot be placed under suspension in a routine manner as part of a "suspension syndrome".

Bar & Bench

The Madhya Pradesh High Court has stayed the suspension of a government primary school teacher who mimicked Prime Minister Narendra Modi in a video satirising the increase in prices of the LPG [Saket Kumar Purohit v The State of Madhya Pradesh and Others]

Justice Ashish Shroti noted that the teacher Saket Kumar Purohit was suspended after Bharatiya Janata Party (BJP) MLA Pritam Lodhi sought action against him. It added that District Education Officer (DEO) suspended Purohit the same day.

"On the very same day, the impugned order came to be passed. It is thus evident that respondent no.3 did not consider the justifiability or desirability of placing the petitioner under suspension. Also, the impugned order does not contemplate any inquiry," the Court said in an order passed on March 25.

Justice Ashish Shroti

The Court added that DEO failed to consider the government instructions as per which a government servant can be placed under suspension only when a major penalty is likely to be imposed.

It observed that an employee cannot be placed under suspension in a routine manner as part of a "suspension syndrome".

"The existence of the power to suspend an employee, the manner in which such power is exercised, and the propriety of passing such an order are distinct aspects. Merely because the authority is competent to issue a suspension order does not place such order beyond the scope of judicial review. If it suffers from non-application of mind or is palpably arbitrary, it is liable to be interfered with," the Bench said.

Purohit, a teacher in Shivpuri district, was placed under suspension on March 13 on the allegation that he posted "an objectionable video" with an intent to cause disturbance in society. He was also accused of damaging the image of the education department.

Challenging the suspension, his counsel argued that the video uploaded by him does not contain any objectionable material which could cause disturbance in society. It was also submitted that he had merely mentioned about the shortage of LPG gas caused by the Israel-Iran war. 

On the other hand, the State said that adjudication of a suspension order would be beyond the purview of judicial review. He has only been placed under suspension, which does not amount to punishment, a government counsel argued.

However, the Court said that the suspension order was passed in haste, allegedly under the dictates of the local MLA and in a routine manner.

Therefore, it said that DEO is required to reconsider the matter by applying his mind and by taking into account the instructions issued by the State government in 2005.

The Court set aside the suspension and remitted the matter to DEO for fresh consideration.

"Since, prima facie , the impugned order dated 13.03.2026 (Annexure P/1) is found to have been passed without consideration of relevant circumstances, its operation shall remain stayed till passing of a fresh order by respondent no.3," the Bench ordered.

Advocate Krishna Kartikey Sharma represented the petitioner.

Government Advocate appeared for the State.

[Read Judgment]

Saket Kumar Purohit v The State of Madhya Pradesh and Others.pdf
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