The country’s highest court has sent out a firm reminder: writ courts are not playgrounds for revisiting disciplinary inquiries unless due process itself has been compromised.
A bench of Justices Rajesh Bindal and Manmohan has overturned the Patna High Court’s decision to reinstate a State Bank of India employee, accused of pocketing bribes while greasing the wheels of loan approvals. With this, the disciplinary authority’s order removing the employee from service now stands restored.
The case concerned Ramadhar Sao, who began his career in SBI as a Class IV worker before rising to the rank of Assistant. Between 2008 and 2010, he allegedly played the role of middleman, sanctioning loans in exchange for money and even disappearing from work without permission. The inquiry report was damning: five loan applicants testified they had paid him directly to get their paperwork cleared.
In 2011, he was dismissed from service. The penalty was later softened to “removal with superannuation benefits.” Sao challenged the decision before the Patna High Court, which ordered his reinstatement with full back wages—an order now quashed by the Supreme Court.
Citing earlier precedent, the Court underscored that judicial review of disciplinary matters is confined to checking for procedural lapses or breaches of natural justice, not to re-assessing evidence as if it were an appellate forum. Justice Bindal noted that Sao never alleged any violation of natural justice; instead, the inquiry had been conducted properly, with evidence duly recorded.
The judgment also clarified that a disciplinary authority’s order cannot be faulted merely because it lacks elaborate reasoning, so long as it accepts the inquiry officer’s well-founded conclusions.
Declaring the High Court’s interference legally unsustainable, the Supreme Court reinstated SBI’s 2012 order: Sao remains removed from service, with only superannuation benefits intact.
