On October 31, 2013, the Supreme Court decided T.S.R. Subramanian v. Union of India. It held that civil servants “cannot function on the basis of verbal or oral instructions, orders, suggestions, proposals, etc.” Oral directions had to be recorded in writing.
The court added: “If the civil servant is acting on oral directions or dictation of anybody, he will be taking a risk.” The lead petitioner, the former Cabinet Secretary T.S.R. Subramanian, said: “Public servants are not private servants.”