State Bank of India v. Ramadhar Sao (2025) – Re-affirming the Narrow Compass of Judicial Review over Departmental Punishments and Clarifying that No Elaborate Reasons Are Required When the Disciplinary Authority Concurs with the Inquiry Report

1. Introduction

State Bank of India v. Ramadhar Sao (2025 INSC 1010) is a landmark Supreme Court decision that revisits the established boundary between judicial review and merits-based appellate scrutiny in service jurisprudence. The case arose from disciplinary proceedings against a Class-IV employee (messenger) of the State Bank of India (“the Bank”) who was found guilty of acting as a middle-man, taking bribes, and remaining unauthorisedly absent. After the Bank’s internal authorities imposed – and later mitigated – a penalty of dismissal to “removal with superannuation benefits”, the employee succeeded before a Single Judge and a Division Bench of the Patna High Court, both of which ordered reinstatement with back wages.

The Supreme Court, per Bindal J., allowed the Bank’s appeal, restored the punishment, and articulated two inter-linked principles:

• Judicial review over disciplinary findings is confined to procedural infirmities, perversity, or violation of natural justice; High Courts cannot sit in appeal on facts or quantum of punishment once due process is observed.
• When the Disciplinary Authority (DA) agrees with the Inquiry Officer’s (IO) report, it need not issue a “reasoned” order beyond recording concurrence; detailed reasoning is necessary only when the DA disagrees with the IO.

2. Summary of the Judgment

After examining the charge-sheet, inquiry record, and High Court orders, the Supreme Court held that:

1. The disciplinary proceedings complied with natural justice – the respondent was served charges, represented by defence assistant, cross-examined witnesses, and responded to the IO report.
2. The IO’s findings were based on testimony of five borrowers who admitted paying bribes; hence the finding of “gross misconduct” was not perverse.
3. The High Court erred in treating the matter as a factual appeal, ignoring binding precedent on the limited scope of judicial review.
4. The DA’s brief order concurring with the IO was valid in law, following SBI v. Ajai Kumar Srivastava and Boloram Bordoloi.
5. The Appellate Authority had already shown leniency by converting “dismissal” to “removal with superannuation benefits”; further interference was unwarranted.

Accordingly, the Supreme Court set aside both tiers of High Court judgments and restored the order dated 07-12-2012 removing the employee from service with superannuation benefits.

3. Analysis

3.1 Precedents Cited and Their Influence

• SBI v. Ajai Kumar Srivastava, (2021) 2 SCC 612: Reiterated that judicial review is confined to correcting errors of law/procedure, not re-appreciation of evidence. The Court quoted paragraph 22 of this decision to emphasise that writ courts are not appellate fora.
• Boloram Bordoloi v. Lakhimi Gaolia Bank, (2021) 3 SCC 806: Held that when the DA agrees with the IO, elaborate reasons are unnecessary; the punishment order may simply reflect concurrence. This directly answered the High Court’s criticism of the alleged “non-speaking” order.
• Earlier general jurisprudence (not expressly cited but underlying): M.V. Bijlani (2006), Union of India v. P. Gunasekaran (2015) – both laying down the boundaries of judicial review in disciplinary matters.

3.2 Court’s Legal Reasoning

1. Procedural Regularity: The Court traced the timeline – show-cause, charge-sheet, inquiry, supply of report, personal hearing – and found no violation of natural justice.
2. Evidentiary Sufficiency: Accepting the IO’s reliance on borrowers’ testimony, the Court held that disciplinary proceedings work on “preponderance of probabilities” rather than “proof beyond reasonable doubt”.
3. Concession/Admission: The employee’s plea for forgiveness (“whatever mistake committed, please forgive me…”) was treated as an implied admission buttressing the findings.
4. Standard of Review: Deploying Ajai Kumar and Gunasekaran principles, the Court reiterated that High Courts should not (i) re-appreciate evidence, (ii) substitute their views on culpability, or (iii) tinker with punishment unless it is “shockingly disproportionate”.
5. Requirement of Reasons: Because the DA concurred with the IO, the brevity of the dismissal order was legally adequate; elaborate reasoning would be redundant.
6. Misplaced Sympathy: While leniency toward a Class-IV employee may appear humane, it cannot override proven corruption; the Bank had already mitigated the penalty.

3.3 Potential Impact of the Judgment

• Service Law Uniformity: The judgment strengthens the uniform principle that High Courts must restrain from acting as appellate authorities in disciplinary matters, harmonising jurisprudence across jurisdictions.
• Departmental Discipline: Public sector banks and other government entities may rely on this ruling to defend disciplinary orders based on concurring, concise punishment orders, thereby reducing procedural challenges.
• Anti-Corruption Stance: Even Class-IV employees can be penalised for bribery; the decision underscores zero-tolerance irrespective of hierarchy.
• Litigation Efficiency: By clarifying that reiterative High Court scrutiny is impermissible absent procedural illegality, the decision should curb protracted service litigation.

4. Complex Concepts Simplified

• Disciplinary Authority (DA): The officer/committee empowered to decide on guilt and impose punishment after inquiry.
• Inquiry Officer (IO): An independent officer who conducts fact-finding, records evidence, and submits a report to the DA.
• Gross Misconduct: Serious breach of service discipline (e.g., corruption, moral turpitude) attracting major penalties such as dismissal or removal.
• Removal vs. Dismissal: Both terminate service; however, removal may preserve certain retirement benefits, while dismissal usually forfeits them. In this case, “removal with superannuation benefits” allowed pensionary benefits.
• Superannuation: Attainment of retirement age (here 30-06-2022 for the respondent); benefits include pension, provident fund, gratuity.
• Show-Cause Notice: A preliminary call asking an employee to explain alleged misconduct before formal charges.
• Charge-Sheet: Formal statement of specific allegations initiating disciplinary proceedings.
• Writ Petition (Article 226): Constitutional petition before a High Court challenging state action. While maintainable, it is limited to legality, not merits.
• Intra-Court Appeal (Letters Patent Appeal): Appeal from a Single Judge to a Division Bench within the same High Court.
• Preponderance of Probabilities: Standard of proof in departmental inquiries; whether a fact is more likely than not, unlike criminal “beyond reasonable doubt”.

5. Conclusion

State Bank of India v. Ramadhar Sao revitalises established yet occasionally diluted propositions: (i) writ courts cannot morph into appellate fact-finders in service matters, and (ii) disciplinary orders need not be minutely reasoned when the authority concurs with an inquiry report. By restoring the Bank’s punishment, the Supreme Court sends a clear signal that proven corruption – even at the lowest rung – warrants stringent action and that misplaced judicial sympathy cannot override institutional discipline.

Going forward, public employers will likely cite this case to defend concise, concurrence-based punishment orders, while employees will have to anchor writ challenges on demonstrable procedural or legal infirmities rather than rearguing facts. The decision thus strikes a pragmatic balance between ensuring fairness in departmental inquiries and safeguarding administrative efficacy.