Judicial review in disciplinary proceedings is limited; concurrent findings supported by evidence and reasons were upheld, and High Court interference was set aside.

Judicial review of disciplinary proceedings is limited to perversity, absence of evidence, jurisdictional error, or breach of natural justice, and does not permit reappreciation of evidence. Where the employee was a joint custodian of cash and keys and concurrent departmental findings on documentary material proved the charges, the High Court could not interfere on an incorrect factual premise. Bare allegations of bias, unproved prejudice from alleged non-supply of documents, and reasons contained in the disciplinary and appellate orders were insufficient to vitiate the inquiry. The High Court was set aside and the modified disciplinary punishment was restored.

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Issues: (i) Whether the High Court could interfere with the disciplinary punishment on the ground that the delinquent employee was not responsible for the cash theft. (ii) Whether the findings in the departmental inquiry were vitiated by bias, non-supply of documents, or inadequacy of reasons in the disciplinary and appellate orders.

Issue (i): Whether the High Court could interfere with the disciplinary punishment on the ground that the delinquent employee was not responsible for the cash theft.

Analysis: Judicial review in disciplinary matters is confined to examining the decision-making process, compliance with natural justice, jurisdiction, and whether the findings are based on some evidence or are perverse. The record showed that the respondent was one of the joint custodians of cash and keys at the relevant time, and the inquiry officer, disciplinary authority, and appellate authority all recorded findings supported by documentary evidence that charges 1 and 4 were proved. The High Court proceeded on an incorrect factual premise and reappreciated the evidence as if sitting in appeal over the departmental findings.

Conclusion: The interference by the High Court was unjustified and the disciplinary finding against the respondent was sustainable.

Issue (ii): Whether the findings in the departmental inquiry were vitiated by bias, non-supply of documents, or inadequacy of reasons in the disciplinary and appellate orders.

Analysis: A bare allegation of bias, unsupported by material, cannot vitiate the inquiry. The respondent also failed to show prejudice from the alleged non-supply of documents, particularly where the inquiry officer recorded that the required record had been made available except confidential material which was open for inspection. The disciplinary and appellate orders were not non-speaking; both contained reasons and reflected consideration of the inquiry record before imposing modified punishment.

Conclusion: The inquiry and the consequential orders were not vitiated on these grounds.

Final Conclusion: The judgment of the High Court was set aside, and the disciplinary action as modified by the appellate authority was restored.

Ratio Decidendi: In judicial review of disciplinary proceedings, courts may interfere only for perversity, absence of evidence, or breach of natural justice, and they cannot reappreciate evidence or overturn concurrent departmental findings supported by some material.

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