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Supreme Court of India 2022-01-19 allowed

Indian Overseas Bank & Ors vs Om Prakash Lal Srivastava

Bench: 2 — Sanjay Kishan Kaul

In Brief

A bank employee (clerk-cum-cashier) was dismissed for forging the signature of his widow sister-in-law to open a joint savings account and withdraw Rs. 20,000 in compensation funds meant for her late husband, along with charges of insubordination and document tampering. The Industrial Tribunal upheld dismissal, but the High Court remitted charges 4–5, requiring expert handwriting opinion. The Supreme Court held that in disciplinary proceedings, the lower standard of 'preponderance of probability' (not criminal 'beyond reasonable doubt') applies. Clear witness testimony from the victim, unchallenged in cross-examination, combined with the officer's signature comparison, sufficed to prove forgery without expert opinion. The High Court wrongly applied criminal standards and interfered without proper grounds. Dismissal was proportionate given the breach of trust by an employee in a fiduciary position.

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Labour and Employment Law Disciplinary Proceedings Fraud and Forgery Evidence Law Handwriting Comparison Standard of Proof High Court Jurisdiction Industrial Dispute Natural Justice Banking Law

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