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Service & Administrative LawSupreme Court of India

K. Prabhakar Hegde v. Bank of Baroda

Civil Appeal · 2025 INSC 997Decided 19 Aug 2025
C.A. No.-006599-006599-2025 (arising out of SLP (Civil) No. 6358 of 2022)
Justice Dipankar Datta · Justice Prashant Kumar Mishra

Background

The appellant, a long-serving Vijaya Bank officer who rose to Zonal Head, faced disciplinary proceedings in 1999 over alleged irregularities in sanctioning temporary overdrafts. Proceedings continued past his retirement date, and in 2002 he was dismissed from service. His departmental appeal was rejected. A Single Judge of the Karnataka High Court quashed the dismissal on natural justice grounds, but a Division Bench reversed this and restored the dismissal, prompting his appeal to the Supreme Court.

Decision Breakdown

The Supreme Court found two genuine natural justice violations: first, the Inquiry Officer never specifically questioned the appellant on the incriminating circumstances as mandatorily required by Regulation 6(17) of the applicable service regulations; second, the appellate authority relied on a Central Vigilance Commission recommendation to enhance his punishment to dismissal, while wrongly withholding that very document from him under an unsubstantiated claim of privilege. Both defects caused real prejudice. However, given the appellant's advanced age (now an octogenarian), the passage of over two decades, and the practical difficulty of reopening records after the bank's 2019 merger, the Court declined to order a fresh inquiry. Instead, it quashed the dismissal but limited relief to a lump-sum payment equivalent to gratuity, without full back wages or other terminal benefits.

Lesson Learnt

Mandatory procedural safeguards in disciplinary inquiries (such as directly questioning an employee on adverse evidence, and disclosing documents relied on to enhance punishment) must be strictly followed, but even a successful natural-justice challenge does not automatically restore full benefits; courts can and do craft practical, proportionate remedies based on real-world circumstances like age and lapse of time.

K. Prabhakar Hegde v. Bank of Baroda – Legal Case Shots | LegalAware