Court’s Decision
The Court dismissed the petition challenging the disciplinary action taken by Punjab National Bank against the petitioner, holding that the findings of the disciplinary and appellate authorities were well-reasoned, supported by evidence, and did not warrant interference under judicial review. The Court reiterated that in service matters involving disciplinary proceedings, interference is justified only when the decision is perverse, mala fide, or contrary to law.
Facts
The petitioner, an employee of Punjab National Bank, faced disciplinary proceedings for alleged misconduct involving irregularities in processing and sanctioning loans. The charges included failure to follow due diligence, breach of internal procedures, and acts leading to financial exposure for the bank. After a departmental inquiry, the Disciplinary Authority imposed a major penalty. The Appellate Authority upheld the penalty, leading to the present writ petition seeking quashing of the orders.
Issues
- Whether the disciplinary proceedings suffered from procedural irregularities violating the principles of natural justice.
- Whether the findings of the Disciplinary and Appellate Authorities were perverse or unsupported by evidence.
- Whether the punishment imposed was disproportionate to the charges proved.
Petitioner’s Arguments
The petitioner contended that the inquiry was vitiated due to non-supply of relevant documents, denial of adequate opportunity to cross-examine witnesses, and reliance on inadmissible evidence. It was argued that the findings were perverse and based on conjectures, without proof of any wrongful gain to the petitioner or loss to the bank. The petitioner further urged that the penalty imposed was grossly disproportionate and warranted interference.
Respondent’s Arguments
Punjab National Bank maintained that the disciplinary proceedings were conducted strictly in accordance with law and principles of natural justice. All relevant documents were supplied, and the petitioner was given ample opportunity to defend himself. The findings were based on documentary evidence, including loan records, and the penalty was proportionate to the gravity of misconduct. The respondent stressed that judicial review in such cases is limited and does not extend to re-appreciation of evidence.
Analysis of the Law
The Court referred to the limited scope of judicial review in disciplinary proceedings, noting that interference is permissible only if the decision is arbitrary, mala fide, or unsupported by evidence. The Court emphasized that it is not the function of the High Court to act as an appellate authority and re-weigh evidence. It also noted that proportionality of punishment is assessed in light of the seriousness of misconduct and its impact on the institution’s integrity.
Precedent Analysis
The Court relied on State Bank of India v. Samarendra Kishore Endow and B.C. Chaturvedi v. Union of India, which held that the High Court should not substitute its own conclusions for that of the disciplinary authority unless findings are perverse or punishment shocks the conscience. It also cited Union of India v. P. Gunasekaran to underline that re-appreciation of evidence is impermissible in judicial review.
Court’s Reasoning
The Court found that the petitioner had been served with a charge-sheet containing detailed allegations and given adequate opportunity to defend himself. The Inquiry Officer’s findings were based on documentary evidence, including loan sanction records that revealed violations of procedural safeguards. The Appellate Authority had considered the petitioner’s submissions and given cogent reasons for upholding the penalty. The Court held that there was no violation of natural justice, no perversity in the findings, and no disproportion in the penalty considering the seriousness of misconduct.
Conclusion
The writ petition was dismissed. The Court affirmed that the disciplinary and appellate orders were well-reasoned, supported by evidence, and in accordance with law. It held that no interference was warranted in the absence of procedural irregularity, perversity, or disproportion in punishment.
Implications
This judgment reinforces the principle that courts will not interfere with disciplinary actions unless there is clear evidence of procedural illegality, mala fides, or perversity. For banking institutions, it underscores judicial deference to internal disciplinary mechanisms, provided they adhere to due process and proportionality.
Cases Referred
- State Bank of India v. Samarendra Kishore Endow – Established that courts should not re-appreciate evidence in disciplinary matters.
- B.C. Chaturvedi v. Union of India – Clarified scope of judicial review and proportionality in disciplinary punishment.
- Union of India v. P. Gunasekaran – Emphasized that interference is limited to jurisdictional errors, procedural irregularities, and perversity.
FAQs
Q1: Can the High Court reassess evidence in a bank disciplinary case?
No. Judicial review is limited to checking procedural fairness, absence of mala fides, and whether findings are supported by evidence.
Q2: What constitutes disproportionate punishment in disciplinary matters?
A penalty is disproportionate if it is grossly excessive relative to the misconduct and shocks the judicial conscience.
Q3: Does the absence of financial loss to the bank negate misconduct?
No. Procedural violations and breaches of duty can justify disciplinary action even without proven financial loss.
