Inquiry report non-supply in disciplinary action does not vitiate dismissal unless actual prejudice affecting the outcome is shown.

Non-supply of an inquiry report does not automatically invalidate a disciplinary dismissal; the employee must show actual prejudice affecting the outcome. The Supreme Court noted that the respondent had received the report before the statutory appeal and had challenged the findings on merits in writ proceedings, so the High Court should not have presumed prejudice without examining its real effect. Given the serious misconduct involving banking integrity, the Court rejected reliance on the earlier charge-sheet and severability reasoning, and held that disciplinary orders are not set aside mechanically for procedural non-furnishing absent demonstrated prejudice.

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Issues: Whether the non-supply of the inquiry report before the disciplinary order caused prejudice to the respondent so as to invalidate the dismissal.

Analysis: The respondent had received the inquiry report before filing the statutory appeal and had also challenged the findings on merits in the writ petition, where the report was annexed and the findings were assailed. The Court held that the High Court erred in assuming prejudice without examining whether non-furnishing of the report actually affected the result. The charges were found to be serious acts of misconduct relating to banking integrity, and the reasoning based on the supposed effect of the earlier charge-sheet and the doctrine of severability was rejected. The Court emphasised that disciplinary orders are not to be set aside mechanically on the mere ground of non-supply of the report, unless real prejudice is shown.

Conclusion: The respondent was not prejudiced by non-supply of the inquiry report in the facts of the case, and the dismissal could not be set aside on that ground.

Final Conclusion: The order of dismissal was restored, and the High Court's interference was reversed.

Ratio Decidendi: Non-supply of the inquiry report does not vitiate a disciplinary dismissal unless the delinquent employee shows actual prejudice affecting the outcome.

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