Judicial review of departmental enquiries is limited; courts cannot reweigh evidence or disturb dismissal absent natural justice violation or disproportionality.

Judicial review of departmental enquiries is limited to cases of breach of natural justice, denial of reasonable opportunity, findings based on no evidence, or punishment that is wholly disproportionate. The High Court cannot reappreciate evidence or act as an appellate authority over the enquiry officer's findings. Here, the employee was found to be the principal organiser in procuring and using forged medical bills, and the disciplinary authority's dismissal was upheld. A discrimination challenge under Article 14 also failed because other employees had admitted misconduct and were differently placed, while no denial of reasonable opportunity was shown. The dismissal was therefore sustained and the High Court's interference was set aside.

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Issues: (i) Whether the High Court could interfere with findings recorded in a departmental enquiry and the punishment of dismissal imposed on the employee; (ii) whether the punishment was discriminatory, violative of Article 14 of the Constitution of India, or imposed in denial of reasonable opportunity.

Issue (i): Whether the High Court could interfere with findings recorded in a departmental enquiry and the punishment of dismissal imposed on the employee.

Analysis: The jurisdiction of the High Court in matters arising out of domestic enquiries is confined to examining whether the enquiry was vitiated by breach of natural justice, denial of reasonable opportunity, findings based on no evidence, or punishment that is wholly disproportionate. The High Court cannot sit in appeal over the enquiry officer's appraisal of evidence or reappreciate the materials as if it were an appellate authority. On the record, the enquiry officer found the employee to be the main actor in procuring and using forged medical bills, a finding accepted by the disciplinary authority and affirmed in appeal.

Conclusion: The High Court was not justified in interfering with the findings and the punishment; the disciplinary order could not be disturbed on judicial review.

Issue (ii): Whether the punishment was discriminatory, violative of Article 14 of the Constitution of India, or imposed in denial of reasonable opportunity.

Analysis: The comparison with other employees was rejected because their cases stood on a different footing: they had admitted the misconduct and were dealt with leniently, whereas the employee concerned was found to be the principal organiser of the fraud. The disciplinary authority was therefore entitled to treat his case differently. The Court also found no material to show that any reasonable opportunity had been denied in the enquiry.

Conclusion: The punishment was neither discriminatory nor disproportionate, and no violation of reasonable opportunity was established.

Final Conclusion: The appeals succeeded and the High Court's orders were set aside, leaving the dismissal from service intact.

Ratio Decidendi: In judicial review of departmental proceedings, interference is permissible only where the enquiry is vitiated by natural justice violations, no evidence, or gross disproportionality; the High Court cannot reassess evidence or substitute its view on punishment merely because other delinquent employees received lesser penalties.

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