The State Bank of India (SBI) appealed a decision from the High Court of Karnataka concerning disciplinary proceedings against an employee. The Division Bench of the High Court upheld the judgment of the Single Judge, who had allowed the writ petition filed by the respondent (employee), thereby quashing an order by the Appointing Authority. The Bank alleged misconduct by the employee during their tenure as a Field Officer. Charges included failure to conduct periodical inspections, non-submission of control forms, and not completing formalities for creating equitable mortgage over collateral property.

The Enquiry Officer conducted an investigation, and the Disciplinary Authority imposed a penalty based on the Enquiry Report’s findings. The Single Judge and Division Bench evaluated the case. The Single Judge classified charges under distinct heads, analyzing evidence and the Enquiry Report’s findings. They held that certain charges lacked proper evidence and found some aspects of the Enquiry Report erroneous.

The Division Bench upheld the Single Judge’s decision, emphasizing that judicial review in disciplinary proceedings should not re-evaluate evidence. It considered the limits of the court’s interference and upheld the decision to quash charges without sufficient evidence.

Analysis:

  1. Charges and Findings: The Bank accused the employee of several charges, including failure to conduct inspections, non-submission of forms, and not creating equitable mortgages. The Enquiry Officer found the employee guilty of some charges but acquitted them on others. The Disciplinary Authority accepted some findings but differed on certain aspects, leading to a penalty.
  2. Judicial Review: The High Court’s role in disciplinary proceedings is to ensure findings are based on evidence, rather than re-evaluating it. The court reviewed whether the findings had any evidence to support them.
  3. Severability of Charges: The court noted that if some charges are proven and the punishment is appropriate for those charges, the overall penalty may be upheld even if other charges are set aside.
  4. Evidence and Findings: The court scrutinized the Enquiry Report, evidence presented, and the findings by the Enquiry Officer and Disciplinary Authority. It found that while some charges lacked adequate evidence, the charge of failure to conduct inspections and not completing mortgage formalities were supported by the evidence.
  5. Appellate Decision: The Division Bench upheld the Single Judge’s decision, highlighting that courts should not interfere with findings if they are based on some evidence.
  6. Conclusion: The court dismissed the respondent’s writ petition and upheld the Bank’s disciplinary action, emphasizing that the role of the court in such matters is not to re-evaluate evidence but to ensure findings are supported by some evidence.

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By aor.sanjivnarang@gmail.com

Sanjiv Narang Adv. is an Advocate on Record in the Supreme Court of India. His qualifications include an LLB from University of Delhi and a Masters degree in Personnel Management from Panjab University,Chandigarh.In his more than 3 decades of experience, he has practiced law at the District, High Court and Supreme Court levels.He also has more than a decade of experience in the field of Management. He is the author of two books namely Laws for Women in India and Innovation, Why What and How.