The Supreme Court has overturned a Rajasthan High Court judgment, where a single judge and a division bench re-evaluated evidence from a departmental enquiry. The Supreme Court, comprising Justices Hima Kohli and Ahsanuddin Amanullah, criticized this action, clarifying that the High Court’s role is not to re-assess evidence in such matters.
The apex court noted the single judge had quashed the findings of a departmental enquiry and a removal order, claiming the conclusions were unsupported by evidence. This decision was upheld by the division bench, which also asserted that the enquiry was flawed and based on no evidence, without providing substantial reasons for this assessment. The Supreme Court found this approach unsustainable, as the High Court’s role under Article 226 of the Constitution does not extend to re-evaluating facts or evidence.
The case involved a departmental enquiry against an Inspector in Rajasthan who faced serious allegations, including embezzlement. After multiple enquiries and judicial reviews, the Inspector was removed from service. However, his removal was repeatedly challenged and overturned by the Rajasthan High Court, leading to the present appeal before the Supreme Court.
Justice Amanullah emphasized that under Article 226, High Courts are not appellate bodies for departmental enquiries. Their role is limited to ensuring the enquiry was conducted by a competent authority, following due process, and upholding natural justice. Unless a decision is shockingly unjust, the High Court should not interfere.
The Supreme Court reiterated that disciplinary authorities are the final judges of facts, provided their findings are based on some legal evidence. The court underlined that while High Courts can review cases for extraordinary infirmities, the threshold for such scrutiny is high.
In conclusion, the Supreme Court ruled that the Rajasthan High Court had overstepped its jurisdiction by re-appraising the evidence and that the departmental enquiry and subsequent removal order were based on sufficient evidence and reasoning. This decision reinforces the limited scope of High Courts in intervening in departmental enquiries, ensuring that administrative authorities retain their designated powers.
