Judicial review in disciplinary proceedings is limited: findings with some evidence stand, and punishment stays with the competent authority.

The SC held that non-supply of the enquiry officer's report did not vitiate the disciplinary order where the governing law applicable to orders passed before the relevant cutoff date did not support that objection. It further found that the disciplinary findings were supported by documentary and other evidence, so they were not based on no evidence or perverse. On judicial review, the High Court could not substitute its own view on the appropriate penalty or interfere merely because a lesser punishment seemed preferable; adequacy of punishment remains primarily for the disciplinary or appellate authority. The disciplinary action was therefore sustained.

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Issues: (i) whether non-supply of the enquiry officer's report before imposing punishment vitiated the disciplinary order; (ii) whether the findings on the proved charges were based on no evidence or were perverse; and (iii) whether the High Court could interfere with the punishment of removal and substitute its own view on the appropriate penalty.

Issue (i): whether non-supply of the enquiry officer's report before imposing punishment vitiated the disciplinary order.

Analysis: The procedural objection was held to be untenable in view of the governing law applicable to orders of punishment passed before the relevant cutoff date. The earlier disciplinary order was not liable to be invalidated on that ground.

Conclusion: The objection failed and was rejected against the respondent.

Issue (ii): whether the findings on the proved charges were based on no evidence or were perverse.

Analysis: The findings on the reimbursement claim, the supporting receipts, the transportation details, and the loan disbursement were supported by documentary material and other evidence. The High Court had misread parts of the enquiry findings and treated them as if they were unsupported, whereas the record disclosed at least some evidence capable of sustaining the conclusions reached by the disciplinary authority.

Conclusion: The findings were not vitiated as being based on no evidence or as perverse.

Issue (iii): whether the High Court could interfere with the punishment of removal and substitute its own view on the appropriate penalty.

Analysis: In disciplinary matters, judicial review is confined to legality, fairness, and evidentiary support. The adequacy of the penalty is primarily for the disciplinary and appellate authorities, and the High Court cannot sit in appeal over the choice of punishment merely because a lesser punishment may appear more suitable. Where misconduct is proved on some evidence, the Court cannot re-evaluate the punishment as an appellate forum.

Conclusion: The High Court was not justified in interfering with the punishment on the ground of excessiveness.

Final Conclusion: The disciplinary action was sustained, and the matter was left to the appellate authority only to consider whether a lesser punishment should be imposed.

Ratio Decidendi: In judicial review of disciplinary proceedings, a finding supported by some evidence cannot be reopened as perverse, and the adequacy of punishment is ordinarily for the competent disciplinary or appellate authority, not the High Court.

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