This Supreme Court judgment reaffirms the limited scope of judicial review in departmental inquiries. The Supreme Court held that constitutional courts cannot act as appellate authorities to re-examine evidence. Interference is permissible only for procedural illegality, natural justice violations, or manifest perversity, not to reassess the merits of the findings recorded by the disciplinary authority.
Facts Of The Case:
The respondent, Ramadhar Sao, was employed as a messenger (a Class-IV employee) with the State Bank of India. In 2008, the Bank received complaints alleging he acted as a middleman, taking bribes from customers to facilitate the sanction and disbursement of loans. A chargesheet was issued against him in 2010, accusing him of misconduct for acting as a conduit for illegal gratification and for unauthorized absence from duty during the subsequent investigation. A departmental inquiry was held where several loan recipients testified, stating they had paid money to the respondent to get their loans approved. The Inquiry Officer found the charges proven. The Disciplinary Authority, after considering the report and the respondent’s plea for mercy citing personal hardships, imposed the penalty of dismissal from service. The Appellate Authority later took a compassionate view and reduced the punishment to “removal from service” with superannuation benefits. Dissatisfied, the respondent challenged this in the Patna High Court. A Single Judge allowed his petition, ordering reinstatement with back wages, primarily reasoning that as a low-ranking employee with no loan-sanctioning power, he was singled out. The Bank’s intra-court appeal was dismissed, leading to the present appeal before the Supreme Court.
Procedural History:
The disciplinary proceedings began with a chargesheet issued to the respondent-employee on January 5, 2010. Following a departmental inquiry that found him guilty, the Disciplinary Authority imposed the penalty of dismissal from service on January 8, 2011. The respondent then filed a statutory appeal, and the Appellate Authority, on December 7, 2012, reduced the punishment to “removal from service” with superannuation benefits. Aggrieved by this, the respondent filed a writ petition (C.W.J.C. No.3594 of 2013) before the Patna High Court. A Single Judge of the High Court, on May 16, 2018, allowed the petition, set aside the punishment, and ordered reinstatement with back wages. The Bank challenged this decision by filing an intra-court appeal (LPA No.1283 of 2018), which was dismissed by the Division Bench of the High Court on December 14, 2022. This dismissal led the Bank to file the present appeal before the Supreme Court, which granted leave and ultimately allowed the appeal, setting aside the High Court’s orders and restoring the Appellate Authority’s punishment of removal from service.
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Court Observation:
The Supreme Court made key observations on the scope of judicial review in disciplinary matters. It emphasized that courts cannot re-evaluate evidence or act as an appellate authority over departmental inquiries. The Court found the inquiry process was fair, with no violation of natural justice, and the findings were based on evidence, including witness testimonies and the employee’s own implied admission of guilt. It held that the disciplinary authority was not required to record detailed reasons when accepting the inquiry officer’s report. The Court concluded that the High Court had exceeded its jurisdiction by interfering with the penalty, which was based on a proper appreciation of evidence concerning misconduct.
Final Decision & Judgement:
The Supreme Court allowed the appeal filed by the State Bank of India. It set aside the orders of both the Single Judge and the Division Bench of the Patna High Court. The Court restored the punishment of “removal from service” with superannuation benefits that was originally imposed on the employee, Ramadhar Sao, by the Bank’s Appellate Authority in its order dated December 7, 2012. The Apex Court held that the High Court had exceeded its limited scope of judicial review by interfering with the findings of the departmental inquiry, which were based on evidence and conducted following due procedure.
Case Details:
Case Title: State Bank of India & Others versus Ramadhar Sao Citation: 2025 INSC 1010 Civil Appeal No.: Civil Appeal No. 10680 of 2025 Date of Judgement: August 20, 2025 Judges/Justice Name: Justice Rajesh Bindal and Justice Manmohan
Download The Judgement Here