On September 21, 2026, Rajveer Singh Verma, a judicial member of the Delhi Bench of the Central Administrative Tribunal (CAT), became the latest judicial officer to recuse himself from a case involving Indian Forest Service (IFS) officer Sanjiv Chaturvedi.
With that, the reported number of judges and judicial officers who have withdrawn from matters involving Chaturvedi rose to 17 over more than a decade. The figure spans the Supreme Court, the Uttarakhand High Court, the CAT and the district judiciary. It includes two Supreme Court judges, four Uttarakhand High Court judges, nine CAT judicial officers and two members of the district judiciary.
The number is extraordinary. But the more difficult question is not simply how many judges have recused themselves. It is why.
The September 21 order offers no explanation. It merely records that after hearing the matter for some time, Justice Verma recused himself and directed the registry to place the case before an appropriate bench. The matter concerns Chaturvedi’s challenge to a November 2021 Uttarakhand government order relating to the Appraisal Report Channel for IFS officers.
There is, however, no established common reason behind the 17 recusals. The circumstances have varied from case to case, and the orders do not establish a single explanation for the judicial withdrawals.
That distinction matters. Recusal is an accepted judicial practice and may be prompted by a possible conflict of interest, a prior association, personal circumstances or a concern about the appearance of bias. But when a long sequence of recusals occurs in cases involving one litigant, and the reasons are not publicly apparent, it inevitably raises questions about transparency and access to justice.
THE FIRST RECUSAL
The sequence goes back to November 2013, when Justice Ranjan Gogoi, then a judge of the Supreme Court, recused himself from a petition filed by Chaturvedi seeking a CBI investigation into allegations of corruption and harassment arising from his tenure in Haryana. In August 2016, Justice UU Lalit, then a Supreme Court judge, recused himself from the same matter. The recusals subsequently spread across other judicial forums.
Among those who have stepped aside are former CAT Chairman Justice L Narasimha Reddy in 2019; CAT judicial member Justice RN Singh in 2021; a bench comprising Manish Garg and Chhabilendra Roul in 2023; and, in February 2025, CAT members Harvinder Kaur Oberai and B Anand. The latter bench made the unusual direction that Chaturvedi’s matters should not be listed before it in future.
In January 2025, CAT judicial member Rajeev Joshi also recused himself from a matter involving Chaturvedi’s central deputation and the Lokpal.
The Uttarakhand High Court has seen several recusals as well. Justice Rakesh Thapliyal stepped aside in May 2023 from a matter concerning records connected with Chaturvedi’s anti-corruption investigations during his tenure as chief vigilance officer at AIIMS. Justice Manoj Tiwari recused himself in February 2024 from a case concerning documents relating to Chaturvedi’s central deputation. In September-October 2025, Justices Alok Verma and Ravindra Maithani recused themselves from a contempt petition filed by Chaturvedi against CAT members and its registry.
The latest recusal, therefore, did not occur in isolation. It added another entry to a judicial history stretching back to 2013.
THE OFFICER AT THE CENTRE OF THE CONTROVERSY
Chaturvedi, a 2002-batch IFS officer, first came into prominence in Haryana, where he was posted at a series of field locations and took up allegations involving illegal tree-felling, poaching, mining, licensing, plantation schemes and other alleged irregularities.
At Kurukshetra, he registered an FIR concerning alleged large-scale illegal tree-felling and poaching in the Saraswati Wildlife Sanctuary. He also raised questions about construction activity inside the Sanctuary without the requisite statutory approvals.
He was transferred to Fatehabad in May 2007. There, he questioned the use of public funds for the development of an herbal park on private land. The controversy brought him into conflict with powerful political and administrative interests. In August 2007, the Haryana government suspended him, and a charge sheet followed.
The suspension was subsequently revoked by President Pratibha Patil in January 2008. The dispute did not end there. Questions over his promotion and service record continued for years.
When posted as divisional forest officer in Jhajjar, Chaturvedi again raised allegations concerning a plantation scheme. The subsequent proceedings against him included disciplinary action over alleged neglect of plantation maintenance. That charge was later rejected by President Pranab Mukherjee in October 2013, with the charge described as unsustainable.
Chaturvedi later became chief vigilance Officer at AIIMS, where he pursued allegations of irregularities and corruption. His disputes with the authorities subsequently generated a series of service and administrative cases involving postings, deputation, disciplinary proceedings and performance appraisals.
His anti-corruption work eventually earned him the Ramon Magsaysay Award, further establishing his public profile as a whistleblower.
FROM FORESTS TO AIIMS
The Haryana chapter was only the beginning.
In May 2012, Chaturvedi was selected for deputation as deputy secretary at AIIMS, New Delhi, under the Union health ministry. His release from the Haryana government became another dispute in the long-running conflict surrounding his service career.
At AIIMS, as chief vigilance officer, he pursued allegations concerning irregularities within the institution and the health sector. His actions brought him into conflict with senior officials and politicians and generated further complaints, investigations and litigation.
One dispute concerned an Intelligence Bureau (IB) report relating to alleged threats and harassment. When Chaturvedi sought access to the report under the Right to Information Act, the Intelligence Bureau resisted disclosure. The Delhi High Court ultimately rejected the IB’s challenge and held that information concerning corruption and human-rights violations did not fall within the relevant exemption from disclosure.
The disputes over his service record continued. His litigation has included challenges to appraisal reports, transfers, deputation decisions and other administrative actions.
It is this accumulation of service and anti-corruption disputes, spread across different governments, institutions and judicial forums, that provides the backdrop to the succession of recusals.
WHAT DOES RECUSAL MEAN?
There is an important distinction between a judicial officer recusing himself or herself and a finding that the officer is biased.
A recusal does not, by itself, establish wrongdoing, conflict or external pressure. Nor does the absence of a stated reason establish that a judge has acted improperly.
Indeed, judicial officers may recuse themselves precisely to preserve—or be seen to preserve—the appearance of impartiality. The difficulty arises when recusals become numerous and the public record offers little explanation.
In Chaturvedi’s case, the individual orders do not reveal one common rationale. Some matters involved service disputes; others concerned anti-corruption investigations, deputation, contempt proceedings or appraisal reports. The circumstances surrounding the recusals have, therefore, differed.
But from the perspective of a litigant, the practical consequence is the same: the matter must repeatedly be placed before another judicial officer.
That is where the larger institutional question begins.
THE TRANSPARENCY PROBLEM
Judicial independence requires judges to have the freedom to recuse themselves where circumstances warrant it. At the same time, the administration of justice depends upon public confidence that cases are being heard by judges who are both impartial and willing to hear them.
The Supreme Court has repeatedly recognised that the purpose of recusal is not merely to avoid actual bias, but also to protect the appearance of impartiality.
Yet, unexplained recusals can create their own problem. When a litigant sees judge after judge stepping aside, the absence of a publicly understandable reason can feed speculation—about conflicts, institutional sensitivities or pressures—that may be entirely unfounded.
That is precisely why the Chaturvedi episode deserves scrutiny without prejudging the reasons for any individual recusal.
There is currently no public evidence establishing that the 17 judicial officers were pressured to withdraw, or that all the recusals stemmed from a common institutional concern. What is established is the number and the breadth of the withdrawals, and the fact that the reasons for many of them are not stated in the orders.
The unanswered question is, therefore, narrower—and more important—than the speculation surrounding it: When an unusually large number of judicial officers withdraw from matters involving one litigant, should the system provide greater institutional transparency about the circumstances of recusal?
THE CONSTITUTIONAL DIMENSION
For Chaturvedi, the issue is not academic. His disputes concern his career, postings, disciplinary proceedings, performance assessments and allegations of retaliation following his anti-corruption activities.
For the judiciary, the issue is broader. Article 14 guarantees equality before the law, while Article 21 protects life and personal liberty through a constitutional framework that includes fair procedure. Access to an impartial adjudicatory process is fundamental to both the legitimacy and credibility of judicial institutions.
The principle that justice must not only be done, but must also be seen to be done acquires particular force when a litigant has spent years moving through different judicial forums.
A succession of recusals does not establish that justice has been denied. But unexplained recusals can make it harder for the public to understand why a particular judge has withdrawn and whether the next forum can provide a clear and effective hearing.
That is the uncomfortable question raised by the Chaturvedi record.
Seventeen judicial officers have stepped aside over 13 years. The latest order gives no reason. The earlier orders, taken together, do not disclose a single explanation.
The law permits recusal. Judicial independence requires it in appropriate cases. But judicial legitimacy also depends upon confidence that a litigant will ultimately find a court willing and able to hear his case.
In the Chaturvedi saga, that remains the unfinished chapter.
—The writer is former Senior Managing Editor, India Legal magazine
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