The Jharkhand High Court reaffirms that, in cases of departmental disciplinary proceedings, High Courts cannot act as appellate authorities to reappreciate evidence and are limited to intervening only for breaches of natural justice or patently perverse decisions. This judgment follows existing Supreme Court precedent, narrowing judicial review and confirming binding authority for similar service law disputes, especially in the banking sector.
Summary
| Category | Data |
|---|---|
| Case Name | WPC/3249/2021 of BASANT KUMAR Vs THE STATE OF JHARKHAND |
| CNR | JHHC010255772021 |
| Date of Registration | 26-08-2021 |
| Decision Date | 30-10-2025 |
| Disposal Nature | Dismissed |
| Judgment Author | Sri Ananda Sen, J. |
| Court | High Court of Jharkhand |
| Precedent Value | Binding on subordinate courts in Jharkhand; strong persuasive value elsewhere |
| Overrules / Affirms | Affirms and follows existing Supreme Court precedent |
| Type of Law | Service law, disciplinary proceedings, writ jurisdiction under Article 226 |
| Questions of Law | What is the scope of High Court interference in disciplinary proceedings and punishment under Article 226? |
| Ratio Decidendi |
|
| Judgments Relied Upon |
|
| Logic / Jurisprudence / Authorities Relied Upon by the Court |
|
| Facts as Summarised by the Court |
Petitioner, a bank employee, was accused of seeking illegal gratification in connection with loan settlements. A departmental inquiry was held, charges were found proven, and a major penalty was imposed. The petitioner alleged violation of natural justice due to non-supply of certain documents and improper inquiry procedure. Respondent argued documents used had been supplied and that the process was fair and complete. The court found the inquiry procedurally sound and the penalty proportionate. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts in Jharkhand; bank disciplinary matters within jurisdiction |
| Persuasive For | Other High Courts and the Supreme Court on disciplinary jurisdiction and service matters |
| Follows |
|
What’s New / What Lawyers Should Note
- Reaffirms that High Courts’ review of disciplinary proceedings under Article 226 is strictly limited—no reappreciation of evidence.
- Clarifies that non-supply of documents is actionable only if the documents were used against the delinquent or if it caused real prejudice.
- Underlines expectation of the highest standard of honesty and integrity from bank officers; minor technicalities will not vitiate proceedings if misconduct is grave.
- Emphasizes that quantum of punishment is the employer’s domain; interference only if it shocks the judicial conscience.
- Provides latest guidance for service lawyers handling bank disciplinary matters on defending or contesting writs.
Summary of Legal Reasoning
- The court reviewed whether the High Court, in exercise of writ jurisdiction, could interfere with disciplinary proceedings and punishments meted out to a bank officer.
- Relied on Supreme Court precedent (Director General of Police, RPF v. Rajendra Kumar Dubey) that High Courts cannot act as appellate bodies or re-examine evidence from departmental inquiries.
- Clarified that interference is permissible only if proceedings violate principles of natural justice, findings are based on no evidence, or rules are violated.
- Affirmed the duty of bank officers to maintain high standards of honesty and integrity (citing Syndicate Bank v. B.S.N. Prasad and associated bank cases).
- Stated that the employer is the primary authority to determine quantum of punishment (Lucknow Kshetriya Gramin Bank v. Rajendra Singh); judicial review is limited to cases where punishment is shockingly disproportionate.
- Found, on facts, that the inquiry was proper, fair hearing was provided, no violation of natural justice occurred, and the penalty was proportionate to the proven misconduct.
Arguments by the Parties
Petitioner
- The penalty order was arbitrary and did not consider the grounds raised in defence.
- Several requests for supply of relevant documents were denied, prejudicing the defence.
- The inquiry was conducted improperly, with no examination of complainants and non-supply of the complaint copy, violating principles of natural justice.
Respondent
- Allegation of illegal gratification and irregular loan settlement was proved in the departmental inquiry.
- All documents used against the petitioner were supplied to him.
- The penalty order was passed after due consideration of the petitioner’s replies.
- Relied on Supreme Court precedents regarding the limited scope of High Court interference in disciplinary proceedings under Article 226.
Factual Background
The petitioner, a staff officer at Jharkhand Rajya Gramin Bank, was accused of seeking illegal gratification relating to loan settlements. After a complaint, he was suspended, and a departmental inquiry was initiated. The petitioner claimed that certain documents were not furnished and that the inquiry process was defective, including lack of examination of the complainant. The disciplinary authority found the charges proved and imposed a major penalty of reduction in pay, which was upheld on appeal. The petitioner challenged these orders by writ petition.
Statutory Analysis
- The court addressed the application of Regulation 39.1(b)(i) of the Jharkhand Rajya Gramin Bank (Officers and Employees) Service Regulations, 2019, which allows for reduction in pay scale as a major penalty.
- Discussed the contours of Article 226 of the Constitution, limiting High Court powers to instances of natural justice breach, absence of evidence, or patent perversion.
- No expansive or narrow reading of statutory provisions was undertaken; instead, the court relied on established interpretations.
Alert Indicators
- Precedent Followed – The court explicitly adheres to Supreme Court precedent governing writ interference in disciplinary proceedings and the proportionality of punishment in employment law in the banking sector.