SC rules FIA employees governed by special 1978 Disciplinary Rules, not Civil Servants Rules 2020

ISLAMABAD, (APP - UrduPoint / Pakistan Point News - 19th May, 2026) The Supreme Court of Pakistan has ruled that departmental proceedings against employees of the Federal Investigation Agency (FIA) can only be conducted under the special Efficiency and Discipline Rules framed in 1978, holding that the Civil Servants Efficiency and Discipline Rules 2020 do not automatically apply to FIA employees.

According to details, the Court clarified that Section 8 of the General Clauses Act could not be used to replace special rules with general rules.

A two-member bench comprising Justice Munib Akhtar and Justice Irfan Saadat Khan announced the reserved judgment in six appeals filed by the FIA.

The Court upheld the decisions of the Federal Service Tribunal and dismissed all appeals filed by the agency.

The judgment stated that the FIA was established under the Federal Investigation Agency Act, 1974, and that the federal government had framed special Efficiency and Discipline Rules for FIA employees in 1978. Through these rules, the 1973 disciplinary framework was adopted with specific modifications tailored for the agency.

The Court observed that although the Civil Servants Efficiency and Discipline Rules 2020 were later introduced, the FIA’s special 1978 rules were neither repealed nor amended in a manner that would make the 2020 rules applicable to FIA employees.

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The Supreme Court held that the Federal Service Tribunal had correctly observed that where a special law and special rules exist, general rules cannot be applied.

The judgment further explained that Section 8 of the General Clauses Act, 1897 applies only in situations where a law specifically refers to provisions of another statute, whereas the FIA’s 1978 rules had adopted the entire 1973 rules framework with amendments.

The Court noted that accepting the FIA’s argument regarding the applicability of Section 8 would effectively render the special 1978 rules redundant, which would be contrary to legislative intent and settled legal principles.

The Supreme Court concluded that departmental actions initiated against FIA employees under the 2020 Rules lacked legal basis and, therefore, no interference was warranted in the judgments passed by the Federal Service Tribunal.