State Bank of India v. Ramadhar Sao
Background
Ramadhar Sao, a messenger with the State Bank of India, was accused of acting as a middleman for illegal gratification while coordinating loan sanctions for bank customers, and of being unauthorizedly absent during the investigation. After a departmental inquiry, the Disciplinary Authority dismissed him from service; on appeal, the punishment was reduced to "removal from service" with superannuation benefits. He challenged even that reduced punishment before the Patna High Court, and both the Single Judge and Division Bench ruled in his favour, ordering his reinstatement with back wages on the ground that the findings against him were based on conjecture and that he had been unfairly singled out.
Decision Breakdown
The Supreme Court held that a court's power of judicial review over disciplinary proceedings is limited to checking for procedural fairness or violations of natural justice. It is not an appeal on the merits, and courts cannot re-weigh the evidence themselves. On the facts, the inquiry had heard five loan customers who testified to paying the employee bribes, another bank officer's evidence supported the case, and the employee's own statement before the Disciplinary Authority ("please forgive me.. I don't have any other source of income") amounted to an implicit admission. The High Court's other stated reasons, that he was singled out while senior officers went unpunished, were also factually wrong, since two other implicated officers had also been removed from service. The Supreme Court restored the Appellate Authority's order of "removal from service" with superannuation benefits.
Lesson Learnt
When a court reviews a disciplinary action taken by an employer under its writ jurisdiction, it can only check whether fair procedure was followed. It cannot act as a second appellate body and substitute its own view of the evidence for that of the inquiry officer and disciplinary authority.