The purpose of a disciplinary proceeding by an employer is to enquire into an allegation of misconduct by an employee which results in a violation of service rules governing relationship of employment. Unlike a criminal prosecution, where charge has to be established beyond reasonable doubt, in a disciplinary proceeding, a charge of misconduct has to be established on a preponderance of probabilities. The rules of evidence which apply to a criminal trial are distinct from those which govern a disciplinary enquiry. The acquittal of accused in a criminal case does not debar employer from proceeding in exercise of disciplinary jurisdiction.

– Hon’ble Justice Dr. D.Y. Chandrachud, State of Karnataka v. Umesh, [Civil Appeal Nos. 1763-1764 of 2022].

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Radheshyam Kejriwal v. State of W.B., (2011) 3 SCC 581 was not noticed in State (NCT of Delhi) v. Ajay Kumar Tyagi, (2012) 9 SCC 685. But, ratio decidendi in Ajay Kumar Tyagi is not regulated by ratio in Radheshyam Kejriwal. We are not convinced this is a fit case where criminal proceedings can be quashed on exoneration in a departmental enquiry. We find Ajay Kumar Tyagi to be squarely applicable.

– Hon’ble Justice K. Vinod Chandran, Karnataka Lokayukta, Bagalkote District v. Chandrashekar, [Special Leave Petition (Crl.) No. 13057 of 2025] decided on 06.01.2026.