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Supreme Court of India 2023-08-24 allowed

State Bank of India vs A.G.D. Reddy

Bench: 2 — J.K. Maheshwari, K.V. Viswanathan

In Brief

The State Bank of India appealed against a High Court order that had quashed a disciplinary penalty imposed on a Field Officer for misconduct. The Supreme Court held that the High Court had overstepped the limited scope of judicial review in disciplinary proceedings by re-appreciating evidence. The Court found that the Enquiry Officer's findings regarding the officer's failure to conduct periodic inspections and failure to secure a loan with offered collateral security were supported by evidence. The burden of proof in such proceedings depends on the nature of the charge; once the employer establishes a prima facie case, the employee must rebut it. The penalty imposed was proportionate to the proven charges. The Court allowed the appeal and set aside the High Court judgments.

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Administrative Law Disciplinary Proceedings Judicial Review Public Service Law Evidence and Burden of Proof Banking Regulation Service Rules

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