Judicial review of departmental enquiries under Article 226 is limited: courts cannot reweigh evidence or act as appellate authorities.

Under Article 226, the High Court cannot reappreciate evidence or sit in appeal over findings in a departmental enquiry; interference is limited to cases of want of jurisdiction, procedural illegality, breach of natural justice, or findings that are perverse or unsupported by any evidence. On the facts, the Tribunal's finding of misconduct was upheld because it rested on available material, including the respondent's own statement and other evidence, and the absence of conductor charts did not make the enquiry unsustainable. The Supreme Court restored the dismissal order and held the High Court's interference with the departmental finding unsustainable.

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Issues: (i) Whether the High Court, in exercise of jurisdiction under Article 226 of the Constitution of India, could reappreciate evidence and interfere with findings recorded in a departmental enquiry; (ii) whether the Tribunal's finding of misconduct was liable to be set aside as unsupported by evidence or vitiated by non-production of certain material.

Issue (i): Whether the High Court, in exercise of jurisdiction under Article 226 of the Constitution of India, could reappreciate evidence and interfere with findings recorded in a departmental enquiry.

Analysis: The supervisory jurisdiction under Article 226 is not an appellate jurisdiction. In disciplinary matters, the High Court may interfere only where the enquiry is conducted by an incompetent authority, in breach of prescribed procedure, in violation of natural justice, or where the finding is unsupported by any evidence or is perverse on its face. Where there is some legal evidence which reasonably supports the conclusion, the adequacy or sufficiency of that evidence cannot be examined in writ proceedings.

Conclusion: The High Court was not entitled to reappreciate the evidence or substitute its own factual conclusions for those of the Tribunal.

Issue (ii): Whether the Tribunal's finding of misconduct was liable to be set aside as unsupported by evidence or vitiated by non-production of certain material.

Analysis: The Tribunal had accepted evidence showing that the respondent had not made the claimed first-class journeys and had relied on material including the respondent's own statement and evidence of ticket purchases by others. The absence of conductor charts did not make the finding one based on no evidence, and the Tribunal's reliance on the available material did not render the enquiry invalid. The challenge that the enquiry resembled a criminal prosecution was rejected, as the standard in a departmental proceeding is not proof beyond reasonable doubt.

Conclusion: The Tribunal's finding was supported by evidence and was not liable to be struck down in writ jurisdiction.

Final Conclusion: The dismissal order was restored and the High Court's interference with the departmental finding was held unsustainable.

Ratio Decidendi: In judicial review of departmental enquiries under Article 226, the High Court cannot act as an appellate authority or reweigh evidence, and it may interfere only if the finding is based on no evidence, is perverse, or the enquiry is vitiated by jurisdictional or natural justice errors.

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