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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, M.M. Sundresh

In Brief

A nationalized bank dismissed an employee (clerk-cum-cashier) for fraud, forgery, and insubordination after departmental inquiry. The Industrial Tribunal upheld the dismissal, but the High Court set aside the finding on forgery charges (4 and 5), requiring expert handwriting analysis. The Supreme Court reversed the High Court, holding that in disciplinary proceedings, the lower standard of preponderance of probability applies (not criminal proof standards). The inquiry officer's signature comparison, corroborated by credible testimony from the sister-in-law whose accounts were fraudulently opened and funds misappropriated, sufficiently proved forgery without mandatory expert evidence. The Court upheld the dismissal as proportionate to the established misconduct.

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Labour Law Disciplinary Proceedings Evidence Handwriting Comparison Fraud and Forgery Standards of Proof Judicial Review Employee Misconduct

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