Patna High Court Upholds Dismissal of Bank Employee for Integrity Violations, Emphasizes Strict Standards for Handling Public Money and No Interference in Disciplinary Actions

Court’s Decision
The Patna High Court dismissed the writ petition challenging the disciplinary actions taken by the Uttar Bihar Gramin Bank against the petitioner, a bank employee. The court upheld the dismissal of the petitioner for serious misconduct, emphasizing the need for utmost integrity in handling public money. The court affirmed the orders passed by both the Disciplinary Authority and the Appellate Authority, refusing to interfere in the bank’s decision to terminate the petitioner’s employment.

Facts
The petitioner, employed as an Office Assistant in Uttar Bihar Gramin Bank, was charged with multiple allegations of misconduct while working at the Ramdauli Branch, Hajipur. A charge memo was issued on December 28, 2018, containing six allegations. The petitioner responded with a defense, but a departmental inquiry found her guilty of the charges. As a result, the Chief Manager-Cum-Disciplinary Authority dismissed her from service on August 16, 2019, a decision upheld by the Appellate Authority on September 19, 2019. The petitioner filed the current writ petition to challenge these actions.

Issues
The primary issue was whether the disciplinary proceedings, including the dismissal order, adhered to the principles of natural justice and whether the petitioner’s rights were violated due to non-supply of crucial documents during the inquiry process.

Petitioner’s Arguments
The petitioner argued that the inquiry process was flawed due to procedural deficiencies, including non-supply of relevant documents such as the Enquiry Report and the Audit Report, which formed the basis of the charges. The petitioner further contended that the actions taken against her were discriminatory, pointing out that another employee, facing similar charges, received only a minor penalty. Additionally, the petitioner claimed that she had deposited cash in her savings account after selling jewelry, which the authorities failed to accept as a valid explanation.

Respondent’s Arguments
The respondent bank defended the disciplinary actions, stating that due process was followed, and all opportunities were provided to the petitioner to defend herself. They argued that the inquiry was conducted fairly, with 53 management documents and multiple witnesses presented. They also rejected the petitioner’s claim of discrimination, noting that the circumstances of her case differed from that of her colleague due to larger sums of money involved in the petitioner’s case.

Analysis of the Law
The court analyzed the compliance of the disciplinary proceedings with the principles of natural justice. It noted that the petitioner was given ample opportunities to defend herself, with 10 inquiry sittings and the presentation of both management and defense witnesses. The court found no procedural lapses that would warrant interference.

Precedent Analysis
The petitioner relied on State of U.P. v. Shatrughan Lal & Anr. and Life Insurance Corporation of India & Ors. v. Triveni Sharan Mishra, arguing that non-supply of documents and unequal treatment in the disciplinary process constituted grounds for quashing the dismissal order. However, the court found that these precedents did not apply as the documents had been made available, and the charges against the petitioner were significantly graver.

Court’s Reasoning
The court reasoned that the nature of the petitioner’s duties, involving financial transactions and public money, required the highest standards of honesty and integrity. The court emphasized that the petitioner’s involvement in unauthorized transactions, as proven in the inquiry, justified the dismissal. The court rejected the claim of discrimination, noting that the petitioner’s situation was not comparable to her colleague’s.

Conclusion
The Patna High Court dismissed the petition, upholding the orders of the Disciplinary and Appellate Authorities. The court found no violation of natural justice and no reason to interfere in the bank’s decision to dismiss the petitioner for misconduct.

Implications
This judgment reinforces the principle that bank employees, particularly those handling public funds, must adhere to the highest standards of integrity. It sets a strong precedent that financial misconduct will not be treated leniently by the courts, even when claims of procedural deficiencies are raised.

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