Breaking Supreme Court Legal Update
New Delhi · Thursday, 06 August 2026 9888666310 | [email protected]
Free Law — free judgments and free headnotes Free Lawby De Jure
Supreme Court of India 2019-12-06 allowed

THE STATE OF BIHAR vs PHULPARI KUMARI

Bench: 2 — L. Nageswara Rao, Hemant Gupta

In Brief

A state government officer (Child Development Officer) was dismissed after being caught red-handed accepting a bribe of Rs. 40,000 in a vigilance raid. A departmental inquiry found her guilty of demanding and accepting illegal gratification. The High Court set aside the dismissal, holding insufficient evidence. The Supreme Court reversed this, restating that judicial review of departmental orders applies only the 'no evidence' test—not sufficiency of evidence. Disciplinary proceedings require only preponderance of probabilities as proof, unlike criminal trials requiring proof beyond reasonable doubt. The Court held the High Court wrongly re-appreciated evidence and substituted the inquiry officer's findings.

The lawyer headnote and full judgment text are available to registered users.

Administrative Law Disciplinary Proceedings Judicial Review Standard of Proof Public Employment Corruption

Read the full judgment & headnote. It's free.

Register to read the complete Supreme Court judgment text and the headnote, and to search 1 lakh+ Supreme Court judgments by meaning. It is a free service.

Register Free Login