A) ABSTRACT / HEADNOTE

The judgment authoritatively delineates the constitutional limits on judicial review under Articles 226 and 227 of the Constitution of India in matters arising from departmental disciplinary proceedings. The Supreme Court examined the legality of interference by the Bombay High Court, Nagpur Bench, which had substituted the punishment of compulsory retirement imposed on a Railway Protection Force officer with reversion in rank and reinstatement with 50% back wages.

The Court reaffirmed that a High Court exercising writ jurisdiction does not function as a court of appeal over disciplinary findings. Re-appreciation of evidence, reassessment of factual conclusions, or substitution of punishment is impermissible unless the disciplinary process is vitiated by violation of principles of natural justice, absence of evidence, perversity, arbitrariness, mala fides, or statutory non-compliance.

The delinquent officer, holding a position of trust as a Sub-Inspector in the Railway Protection Force, was found guilty of gross neglect of duty leading to theft of railway property and consequent pecuniary loss. The Supreme Court emphasized the heightened standard of integrity expected from personnel entrusted with protection of public property.

By restoring the order of compulsory retirement, the Court underscored that proportionality of punishment must be assessed with reference to the nature of duties, gravity of misconduct, and institutional discipline, and not on sympathetic considerations. The ruling consolidates long-standing service jurisprudence restricting judicial intervention in disciplinary matters and reinforces administrative autonomy in maintaining discipline within uniformed forces.

Keywords: Judicial Review, Compulsory Retirement, Departmental Enquiry, Proportionality of Punishment, Service Law

B) CASE DETAILS

C) INTRODUCTION AND BACKGROUND OF JUDGMENT

The judgment arises from a service dispute concerning disciplinary control within the Railway Protection Force, a uniformed force constituted for safeguarding railway property and passengers. The case reflects institutional tension between administrative discipline and judicial oversight.

The respondent officer was subjected to major penalty proceedings for gross neglect of duty involving repeated thefts of railway property and procedural lapses such as failure to register FIRs and submit case diaries. These acts were treated as serious misconduct because they compromised statutory duties under Section 11 of the Railway Protection Force Act, 1957.

The departmental hierarchy initially imposed removal from service, later reduced in appeal to reversion in rank. Subsequently, exercising review powers under Rule 219.4 of the Railway Protection Force Rules, 1987, the competent authority enhanced the punishment to compulsory retirement, citing gravity of misconduct and institutional integrity.

The High Court, invoking writ jurisdiction, interfered with this decision by reassessing factual findings and modifying punishment. The Supreme Court was therefore called upon to examine whether such interference conformed to settled principles governing judicial review of disciplinary proceedings.

This judgment situates itself within a long line of precedents emphasizing restraint by constitutional courts in service matters, particularly involving disciplined forces. It also reinforces the doctrine that administrative authorities are best placed to assess discipline, trust, and operational standards.

D) FACTS OF THE CASE

The respondent joined the Railway Protection Force in 1984 and was posted as Sub-Inspector (Adhoc) at Pulgaon Railway Station in 2006. During his tenure, multiple thefts of railway property were reported within his jurisdiction, including CST-9 plates and a coach trolley valued at ₹28,000.

A charge sheet was issued under Rule 153 of the Railway Protection Force Rules, 1987, alleging gross neglect of duty and abuse of authority. The Enquiry Officer found charges relating to neglect of duty proved while partially exonerating the respondent.

The Disciplinary Authority imposed removal from service. On appeal, the punishment was diluted to reversion in rank on the ground that there was no direct evidence of corruption or connivance.

Subsequently, invoking Rule 219.4, the Reviewing Authority issued a show-cause notice proposing enhancement of punishment. The review considered the seriousness of repeated neglect, loss to public property, and erosion of public confidence in the Force. The respondent was compulsorily retired with immediate effect.

The final departmental appeal was rejected. The respondent approached the High Court, which interfered by re-evaluating factual aspects, discarding certain charges, and restoring the appellate order with reinstatement and back wages. This prompted the present civil appeal before the Supreme Court.

E) LEGAL ISSUES RAISED

i. Whether the High Court exceeded its jurisdiction under Articles 226 and 227 by re-appreciating evidence in a departmental enquiry?
ii. Whether substitution of punishment by the High Court was legally sustainable?
iii. Whether compulsory retirement was disproportionate to the proved misconduct?

F) PETITIONER / APPELLANT’S ARGUMENTS

The counsels for the appellants submitted that the High Court acted as a court of first appeal by reassessing evidence and factual conclusions. It was argued that the enquiry was conducted strictly in accordance with statutory rules, with full opportunity of hearing.

Reliance was placed on State of Andhra Pradesh v. S. Sree Rama Rao and Union of India v. P. Gunasekaran to contend that judicial review does not permit re-evaluation of evidence or proportionality unless punishment shocks the conscience.

G) RESPONDENT’S ARGUMENTS

The counsels for the respondent contended that the punishment was excessive and not commensurate with misconduct. It was argued that thefts were detected by other officers and that there was no allegation of corruption in the charge sheet.

The High Court’s reasoning was defended on grounds of proportionality and fairness.

H) JUDGMENT 

The Supreme Court allowed the appeal and restored the order of compulsory retirement. The Court held that none of the legally recognized grounds for judicial interference were present.

It reiterated that disciplinary authorities are the sole judges of facts when enquiries are conducted lawfully. The High Court erred in reassessing evidence and substituting punishment without finding perversity or violation of natural justice.

The Court emphasized that personnel of the Railway Protection Force discharge duties of trust and confidence. Proven neglect resulting in loss of railway property justified major penalty. Directions for reinstatement and back wages were held unsustainable.

a) RATIO DECIDENDI

The High Court, while exercising jurisdiction under Articles 226 and 227, cannot re-appreciate evidence or modify punishment imposed in departmental proceedings unless the findings are perverse, arbitrary, or unsupported by evidence. Compulsory retirement for gross neglect of duty in a disciplined force does not warrant judicial interference when enquiry is fair and lawful.

b) OBITER DICTA

The Court observed that integrity standards in uniformed services are inherently higher and disciplinary autonomy is essential for institutional credibility. Judicial sympathy cannot replace statutory discipline.

c) GUIDELINES

i. Writ courts must exercise restraint in service matters.
ii. Re-appreciation of evidence is impermissible.
iii. Punishment can be interfered with only when shockingly disproportionate.

I) CONCLUSION & COMMENTS

The judgment consolidates service jurisprudence limiting judicial review in disciplinary matters. It reinforces the doctrine of administrative autonomy and underscores the critical importance of integrity in public service. The ruling serves as a binding precedent cautioning High Courts against substituting disciplinary discretion with judicial assessment.

J) REFERENCES

a) Important Cases Referred

1. State of Andhra Pradesh v. S. Sree Rama Rao, AIR 1963 SC 1723
2. Union of India v. P. Gunasekaran, [2014] 13 SCR 1312
3. B.C. Chaturvedi v. Union of India, [1995] 4 Supp SCR 644

b) Important Statutes Referred

1. Constitution of India
2. Railway Protection Force Act, 1957
3. Railway Protection Force Rules, 1987