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State Bank of India vs A.G.D. Reddy

Civil Appeal · 2023 INSC 766Decided 24 Aug 2023
Civil Appeal No. 11196 of 2011
J.K. Maheshwari · K.V. Viswanathan

Background

The respondent, a Field Officer at an SBI branch, was departmentally charged with misconduct, including failing to conduct periodical inspections of loan accounts, not completing formalities to create an equitable mortgage as collateral for one borrower, and other lapses. After an inquiry, the Disciplinary Authority found several charges proved and imposed a penalty of reduction in basic pay, which the Appellate Authority upheld; however, both a Single Judge and a Division Bench of the Karnataka High Court quashed the punishment, holding the enquiry officer's findings were based on no real evidence. The Bank appealed to the Supreme Court.

Decision Breakdown

The Supreme Court re-examined the actual deposition and enquiry record and found that the High Court had gone beyond its limited power of judicial review by re-appreciating evidence like an appellate court. On the specific charges of failing to conduct periodical inspections and failing to secure a collateral mortgage for one borrower (M/s Saraswathi Fabricators), the Court found there was, in fact, evidence on record (witness testimony and documents) supporting the enquiry officer's findings, so these findings could not be called "perverse" or based on "no evidence." Applying the settled principle that a High Court under Article 226 cannot substitute its own view of the evidence for that of the disciplinary authority as long as some evidence supports the finding, and that a penalty can stand even if not every charge was proved (severability of charges), the Court restored the punishment and dismissed the respondent's writ petition.

Lesson Learnt

Courts reviewing departmental disciplinary proceedings under writ jurisdiction cannot act as an appellate body re-weighing evidence. They may only check whether the enquiry followed fair procedure and whether some evidence supports the findings; if it does, the punishment stands even if a few individual charges were not proved.

Official source (sci.gov.in)View Judgment (PDF)

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