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Issues Involved:
1. Validity of the disciplinary authority's decision. 2. Proportionality of the punishment imposed. 3. Procedural irregularities in the disciplinary proceedings. 4. Judicial review of administrative decisions. Detailed Analysis: 1. Validity of the Disciplinary Authority's Decision: The appellant, an officer in Allahabad Bank, faced disciplinary proceedings for alleged irregularities. Charges included allowing advances without adhering to norms, failing to obtain necessary documentation, and extending benefits improperly. The disciplinary authority found him guilty of some charges and ordered his removal from service. The appellant's appeal against this decision was unsuccessful, leading him to file a writ petition. He argued that the dismissal order was passed by an authority junior to the appointing authority, violating Article 311 of the Constitution of India. However, the High Court ruled against the appellant on all points, including this one. 2. Proportionality of the Punishment Imposed: The appellant contended that the punishment of removal from service was disproportionate to the charges. The High Court, referencing the Supreme Court's decision in State Bank of India & Ors. vs. Samerendra Kishore Endow & Anr., held that the imposition of punishment was within the discretion of the disciplinary authority and not subject to judicial review. The Supreme Court, however, considered whether the punishment was "shockingly disproportionate" and noted that the appellant had more than 30 years of unblemished service. The Court found that procedural irregularities did not equate to misconduct warranting dismissal. 3. Procedural Irregularities in the Disciplinary Proceedings: The charges against the appellant included allowing advances without observing norms, failing to obtain completion reports, and not verifying electricity for pump sets. The appellant argued that these irregularities did not amount to misconduct or dishonest intention. The Supreme Court noted that the High Court did not properly consider whether these procedural irregularities justified the extreme punishment of dismissal. The Court emphasized that procedural irregularities should not be conflated with negligence warranting dismissal. 4. Judicial Review of Administrative Decisions: The Supreme Court examined the scope of judicial review in administrative law, particularly concerning the principle of proportionality. Citing Union of India & Anr. vs. G.Ganayutham and B.C.Chaturvedi vs. Union of India & Ors., the Court discussed the limited power of judicial review concerning the quantum of punishment. It reiterated that courts could interfere if the punishment was "outrageous defiance of logic" or "shockingly disproportionate." The Court found that the High Court did not consider relevant factors affecting the quantum of punishment, such as the appellant's long service and lack of previous misconduct. Conclusion: The Supreme Court set aside the High Court's order and remitted the case for reconsideration of the quantum of punishment. The High Court was directed to examine the proportionality of the punishment afresh, considering the appellant's service record and the nature of the irregularities. The appeal was disposed of with no order as to costs, and the High Court was requested to expedite the matter within six months.
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