The Delhi High Court in SH D.C. NARNOLIA v. CANARA BANK AND ORS observed that the Courts while exercising jurisdiction under Article 226 or 227 of the Indian Constitution, in cases of departmental enquiries, cannot reappreciate evidence which has already been reasonably considered by the departmental authorities.
The Court further stated that it is settled law that the High Court, in the exercise of its powers under Articles 226/227 of the Constitution of India, shall not venture into reappreciation of the evidence. The High Court can only see whether:
(a) the Inquiry is held by a competent authority;
(b) the Inquiry is held according to the procedure prescribed in that behalf;
(c) there is violation of the principles of natural justice in conducting the proceedings;
(d) the authorities have disabled themselves from reaching a fair conclusion by some considerations extraneous to the evidence and merits of the case;
(e) the authorities have allowed themselves to be influenced by irrelevant or extraneous considerations;
(f) the conclusion, on the very face of it, is so wholly arbitrary and capricious that no reasonable person could ever have arrived at such conclusion;
(g) the disciplinary authority had erroneously failed to admit the admissible and material evidence;
(h) the disciplinary authority had erroneously admitted inadmissible evidence which influenced the finding;
(i) the finding of fact is based on no evidence.
It further held that under Articles 226/227 of the Constitution of India, the High Court shall not:-
(i) reappreciate the evidence;
(ii) interfere with the conclusions in the Inquiry, in case the same has been conducted in accordance with law;
(iii) go into the adequacy of the evidence;
(iv) go into the reliability of the evidence;
(v) interfere, if there is some legal evidence on which findings can be based.
(vi) correct the error of fact however grave it may appear to be;
(vii) go into the proportionality of punishment unless it shocks its conscience.