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Issues:
- Appeal against judgment of Madhya Pradesh High Court allowing writ petition. - Grounds of non-supply of Enquiry Officer's report, failure to provide fresh notice, and passing a non-speaking order. - Interpretation of Rule 51(2) regarding speaking order by appellate authority. Analysis: The case involves an appeal against the judgment of the Madhya Pradesh High Court, where the respondent, a Branch Manager at State Bank of India, faced a disciplinary inquiry resulting in removal from service. The Enquiry Officer found some charges established, while the disciplinary authority disagreed on certain charges. The respondent's appeal to the appellate authority was dismissed, leading to a writ petition in the High Court based on three grounds: non-supply of Enquiry Officer's report, lack of fresh notice upon disagreement by appellate authority, and passing a non-speaking order violating natural justice principles. The Supreme Court addressed each ground, citing precedent to reject the first contention based on the timing of the punishment order. Regarding the second ground, the Court emphasized that the Enquiry Officer's report is not binding on the disciplinary authority, allowing independent conclusions on charges. The Court highlighted that the disciplinary authority can conduct the inquiry itself or appoint an Enquiry Officer, with the final decision resting with the authority. The second contention was thus rejected. The third ground focused on Rule 51(2) requiring the appellate authority to pass a speaking order. The High Court's view was that even in cases of affirmation, a speaking order is mandatory. The Supreme Court disagreed, finding the appellate order sufficiently detailed as it considered the case facts, grounds of appeal, and reasons for dismissal. The Court concluded that the order demonstrated the application of mind, making it unnecessary for the appellate authority to provide further reasoning in an affirming order. Consequently, the Court allowed the appeal, setting aside the High Court's order and reinstating the punishment without costs.
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