Article 226 writs can reach co-operative bank service actions, while summary terminations and account freezes were set aside.

A co-operative bank may fall outside Article 12 and still be amenable to writ jurisdiction under Article 226 where its statutory and certified service obligations amount to a public duty. The bank's summary termination of employees without notice, hearing, or compliance with the certified Standing Orders was treated as contrary to natural justice and illegal, so the termination orders were quashed with consequential relief. The bank also could not freeze an ex-manager's savings account merely on apprehended liability after his resignation had been accepted; access to the account was restored subject to furnishing the stipulated security bond.

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Issues: (i) Whether a writ petition under Article 226 of the Constitution of India was maintainable against the District Central Co-operative Bank despite the Bank not being a State or authority under Article 12; (ii) Whether the termination of the employees was sustainable in view of the Standing Orders and principles of natural justice; and (iii) Whether the order freezing the ex-Manager's savings account could stand.

Issue (i): Whether a writ petition under Article 226 of the Constitution of India was maintainable against the District Central Co-operative Bank despite the Bank not being a State or authority under Article 12.

Analysis: The Bank was found not to satisfy the test of State or instrumentality under Article 12, since there was no deep and pervasive governmental control, no substantial State shareholding, and the statutory supervision under the co-operative law and banking regulatory framework was not enough by itself to convert the Bank into a State authority. However, Article 226 was held to be wider in scope and capable of being invoked against any person or body performing a public duty. The Bank's obligations under the certified Standing Orders and the co-operative regulatory framework were treated as duties enforceable in public law.

Conclusion: The writ petitions were maintainable under Article 226, even though the Bank was not an authority under Article 12.

Issue (ii): Whether the termination of the employees was sustainable in view of the Standing Orders and principles of natural justice.

Analysis: The employees had been appointed and were in service under various statuses, including probation, regular appointment, and daily-wage absorption. The certified Standing Order governing termination required notice or wages in lieu thereof and recording of reasons, but the services were terminated summarily on the same day by the new management. The action was found to have been taken in hot haste, without notice or hearing, and in a manner showing extraneous purpose and mala fides in law. The absence of compliance with the Standing Orders and the denial of an action-inspired notice rendered the termination illegal.

Conclusion: The termination orders were quashed and the employees were held entitled to consequential reliefs.

Issue (iii): Whether the order freezing the ex-Manager's savings account could stand.

Analysis: The petitioner had already resigned and his resignation had been accepted. His terminal dues had been credited to his savings account, and the Bank could not withhold operation of the account merely on the basis of apprehended liability or pending suspicion. The Bank was entitled, at most, to require the agreed security bond and proceed in accordance with law if any inquiry was to be held, but it could not deny the account holder access to his own deposit.

Conclusion: The freezing of the account was set aside, and the petitioner was permitted to operate the account upon furnishing the stipulated security bond.

Final Conclusion: The common judgment granted relief in both sets of matters: the employee terminations were invalidated, and the ex-Manager was allowed to operate his account subject to furnishing security, thereby giving the petitioners substantial relief under Article 226.

Ratio Decidendi: A co-operative bank may not be a State under Article 12, but its statutory and certified service obligations, including standing orders, can be enforced under Article 226 where the impugned action violates public duty, natural justice, and the governing service conditions.

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