Punishment Imposed By Disciplinary Authority Can Be Interfered With Only If It Is Strikingly Disproportionate: SC
Principle: Interference with Punishment Imposed by Disciplinary Authority
Disciplinary authorities are empowered to impose punishment on employees or service personnel for misconduct.
The courts generally do not interfere with the punishment awarded by such authorities.
However, judicial interference is warranted if the punishment is “strikingly disproportionate”, arbitrary, unreasonable, or violates principles of natural justice.
The courts act as corrective forums ensuring fairness, not to substitute their own discretion for that of the disciplinary authority.
Rationale
Domain of Expertise
Disciplinary authorities have expertise and firsthand knowledge of service rules, conduct, and context.
Separation of Powers
Courts should respect administrative decisions unless there is gross injustice.
Preventing Abuse of Authority
Judicial review acts as a safeguard against excessive or vindictive punishment.
Balancing Justice and Discipline
Courts ensure punishment is proportionate to misconduct, preserving service discipline.
Important Supreme Court Case Laws
1. Union of India v. Tulsiram Patel, AIR 1985 SC 1416
Held: Courts should not interfere in the exercise of disciplinary powers except when punishment is so harsh or excessive as to shock the conscience of the court.
Punishment should bear a reasonable relation to the misconduct.
2. Municipal Corporation of Delhi v. Female Workers (Muster Roll), (2000) 3 SCC 224
The Court stated that judicial interference in disciplinary matters is justified only when the punishment is wholly disproportionate or without application of mind.
3. S.L. Kapoor v. Jagmohan, AIR 1981 SC 1361
It was held that courts cannot substitute their own opinion on the quantum of punishment unless the penalty is manifestly excessive or mala fide.
4. State of Punjab v. Jagjit Singh, (2016) 11 SCC 639
Reinforced that the punishment awarded by the disciplinary authority should be interfered with only if it is shockingly disproportionate or without any basis.
5. Central Bank of India v. Ravindra, (2017) 5 SCC 580
Judicial interference in the choice of punishment is the last resort and courts must respect the administrative discretion unless it is arbitrary, capricious, or unreasonable.
Application
When an employee challenges a disciplinary punishment, courts review:
Was due process followed?
Was the punishment proportionate to the misconduct?
Was there any arbitrariness or mala fide intention?
Mere leniency or severity difference of opinion is not sufficient to interfere.
The test is whether the punishment “shocks the conscience” or is “strikingly disproportionate” to the offence.
Summary
Courts respect the disciplinary authority’s domain and discretion.
Interference is limited to cases where punishment is:
Strikingly disproportionate
Arbitrary
Unreasonable
Passed without due procedure
This principle balances the need for discipline with protection of rights.
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