Writ jurisdiction over a statutorily controlled co-operative bank upheld, while disciplinary dismissals survived compliance review.

A co-operative land development bank controlled by statutory service regulations and State-appointed management was treated as amenable to writ jurisdiction under Article 226 because pervasive State control and public statutory duties brought it within constitutional review. The disciplinary action was upheld because the employees received charge-sheets, access to relied-upon material, an opportunity to inspect documents, submit explanations, and participate in the inquiry, and the governing service regulations and natural justice requirements were followed. The absence of a separate detailed dismissal order did not, by itself, vitiate the proceedings where the prescribed procedure had been complied with.

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Issues: (i) Whether the appellant co-operative bank was amenable to writ jurisdiction under Article 226 of the Constitution of India as an authority or instrumentality of the State; (ii) Whether the dismissal orders were vitiated for non-compliance with the statutory service regulations and the principles of natural justice.

Issue (i): Whether the appellant co-operative bank was amenable to writ jurisdiction under Article 226 of the Constitution of India as an authority or instrumentality of the State.

Analysis: The appellant was constituted under the statutory scheme governing co-operative land development banks and its service conditions were controlled by the State through statutory regulations and a service board. The appointment, approval, and disciplinary control over employees were regulated by statutory provisions, and the managing officers were State officials on deputation. On the facts, the control of the State Government was pervasive and the appellant performed a public function with statutory obligations. In such circumstances, the form of the body as a co-operative society did not exclude it from the reach of Article 226.

Conclusion: The appellant was amenable to writ jurisdiction under Article 226 and was an authority controlled by the State.

Issue (ii): Whether the dismissal orders were vitiated for non-compliance with the statutory service regulations and the principles of natural justice.

Analysis: The employees were served with charge-sheets containing specific charges, were informed of the evidence relied upon, were given opportunity to inspect documents, submit explanations, and appear before the inquiry officer. The disciplinary process and the post-inquiry steps were conducted in accordance with the applicable statutory regulations, which governed disciplinary control and required observance of natural justice. The absence of a different procedural format or a separate elaborate speaking dismissal order did not establish violation where the prescribed statutory procedure had been followed.

Conclusion: The dismissal orders were not vitiated, and the disciplinary proceedings were held valid.

Final Conclusion: The challenge to the maintainability of the writ petition failed, but the merits of the disciplinary action were upheld, resulting in restoration of the dismissal orders and rejection of the employees' writ petitions.

Ratio Decidendi: A co-operative society or bank may be subjected to writ jurisdiction where it is created and controlled by statute, the State's control over its affairs is pervasive, and the impugned action concerns enforcement of statutory service obligations and public duties; disciplinary orders passed after compliance with the governing regulations and fair hearing requirements are not invalid merely because they are not accompanied by a detailed separate reasoning order.

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