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The General Manager Personnel, Syndicate Bank v. B S N Prasad

Civil Appeal · 2025 INSC 89Decided 21 Jan 2025
Civil Appeal No. 6327 of 2024
Justice Abhay S. Oka · Justice Augustine George Masih

Background

The respondent, a branch manager at Syndicate Bank, was dismissed after a disciplinary inquiry found he had made fictitious debits, exceeded sanctioned loan limits, and misappropriated funds while managing customer accounts. He challenged the dismissal, and the High Court (both the Single Judge and Division Bench) set it aside, holding there was "no evidence" against him and that the inquiry violated natural justice, ordering his reinstatement with full back benefits. The Bank appealed to the Supreme Court.

Decision Breakdown

The Supreme Court held that the High Court had wrongly reappraised the evidence, which is not permitted in judicial review of a disciplinary inquiry: the correct test is only whether there was "some evidence" supporting the findings, and here the respondent had, in written replies, admitted most of the irregularities and voluntarily repaid the misappropriated amounts, so it was clearly not a "no evidence" case. However, the Court also found that a dismissal was too harsh a punishment given the respondent's otherwise unblemished 21-year career and the fact that the bank's financial loss had been fully recovered, so it modified the penalty to a lesser one: reduction to a lower pay stage for one year, without affecting his pension.

Lesson Learnt

Courts reviewing a disciplinary dismissal cannot re-weigh the evidence themselves. They may only check whether some evidence exists and whether the punishment is proportionate to the proven misconduct, and can reduce an excessive penalty even while upholding the underlying finding of guilt.

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

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