Summary
| Category | Data |
|---|---|
| Court | Supreme Court of India |
| Case Number | C.A. No.-013183-013183 – 2025 |
| Diary Number | 28631/2025 |
| Judge Name | HON’BLE MR. JUSTICE RAJESH BINDAL |
| Bench | HON’BLE MR. JUSTICE RAJESH BINDAL; HON’BLE MR. JUSTICE MANMOHAN |
| Precedent Value | Binding authority on subordinate courts |
| Overrules / Affirms | Affirms existing precedent restricting scope of judicial review in disciplinary matters |
| Type of Law | Administrative / Service Law |
| Questions of Law |
|
| Ratio Decidendi |
The High Court exceeded its jurisdiction by delving into the merits of the disciplinary inquiry. Judicial review under Article 226 (and inherent powers) is confined to procedural fairness, not re-assessment of evidence or facts. Even though the respondent deposited the misappropriated funds, that does not negate the misconduct. No infirmity in the inquiry process was shown; therefore, the removal penalty was valid and must be upheld. |
| Logic / Jurisprudence / Authorities Relied Upon by the Court |
The Court analysed the charges (Articles I & II), noted admission of guilt and absence of procedural defect, and held that voluntary deposit of funds does not defeat proved misconduct. It reaffirmed that courts cannot substitute their view for disciplinary authorities when inquiry is regular. |
| Facts as Summarised by the Court |
The respondent, a Gramin Dak Sevak/Branch Postmaster since 1998, misappropriated recurring-deposit instalments and insurance premiums between 2010–11, admitted the omissions under inquiry, was removed, lost appellate remedies up to the High Court, which set aside the penalty by re-evaluating merits. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts and tribunals |
What’s New / What Lawyers Should Note
- The judgment clarifies that judicial review of departmental disciplinary proceedings under Article 226 and inherent powers is limited to procedural regularity and does not extend to re-weighing evidence or merits.
- Admission of guilt and subsequent deposit of misappropriated funds cannot, by themselves, absolve an employee of proven misconduct.
- High Courts must refrain from substituting their own assessment of departmental losses or staff credibility where no legal infirmity in the inquiry process is shown.
Summary of Legal Reasoning
- Scope of Judicial Review: The Court reaffirmed that High Courts can only examine whether disciplinary authorities complied with service rules and afforded fair hearing—not re-evaluate findings of fact.
- Proof of Misconduct: Articles of charge (misappropriation of RD instalments and insurance premiums) were proven by documentary evidence (stamped passbooks without ledger entries) and admissions.
- Procedural Regularity: The respondent was served a chargesheet, given defence assistance, cross-examined witnesses, and addressed the Disciplinary Authority. No procedural defect was alleged.
- Voluntary Deposit Irrelevant to Innocence: Repayment of the amount does not nullify misconduct once charges are proved.
- High Court’s Error: By delving into the admission under alleged duress and re-assessing explanation, the High Court exceeded judicial review limits.
Arguments by the Parties
Petitioner (Union of India and Ors.)
- The High Court over-stepped its jurisdiction by examining the merits of the inquiry.
- No defect in the inquiry or denial of fair hearing was shown.
- Respondent’s guilt was admitted and proven; deposit of funds was voluntary but does not absolve misconduct.
Respondent (Indraj)
- Admission of guilt was made under undue influence by the Inspector.
- Depositors did not complain; repayment showed good faith.
- High Court correctly set aside the removal order.
Factual Background
The respondent was appointed as Gramin Dak Sevak/Branch Postmaster in 1998. During a 2011 inspection, he was found to have collected recurring-deposit instalments and insurance premiums without crediting them to government accounts, keeping Rs. 1900 and Rs. 3366 respectively for personal use. A departmental inquiry was held, he admitted spending the amounts, and was removed. He exhausted appeal remedies, then obtained relief from the High Court, which the Supreme Court has now set aside.
Statutory Analysis
- Gramin Dak Sevak (Conduct and Engagement) Rules, 2011:
- Rule 21: Duty of integrity and devotion to duty.
- Branch Post Office Manual, 6th Edition:
- Rule 131: Maintenance of account books and deposit procedures.
- The Court held that breach of these rules, once proved, justifies removal even if funds are later restored, and that judicial review does not permit re-interpretation of service rules beyond procedural compliance.
Alert Indicators
- ✔ Precedent Followed – The decision reaffirms existing law on the limited scope of judicial review in service disciplinary matters.