State of Andhra Pradesh v. S. Sree Rama Rao, AIR 1963 SC 1723; State of Andhra Pradesh v. Chitra Venkata Rao, (1975) 2 SCC 557; State Bank of India v. S.K. Sharma, (1996) 3 SCC 364; Union of India v. K.G. Soni, (2006) 6 SCC 794; State of Uttar Pradesh v. Man Mohan Nath Sinha, (2009) 8 SCC 310; State Bank of India v. Ram Lal Bhaskar, (2011) 10 SCC 249.

Turning our gaze back to facts herein, we find, Learned Single Judge and Division Bench acted as Courts of Appeal and went on to re-appreciate evidence, which above-enumerated authorities caution against.

It is well-settled, if disciplinary authority accepts findings recorded by Enquiry Officer and proceeds to impose punishment, no elaborate reasons are required as explained by Boloram Bordoloi v. Lakhimi Gaolia Bank, (2021) 3 SCC 806.

– Hon’ble Justice Ahsanuddin Amanullah, State of Rajasthan v. Bhupendra Singh, [Civil Appeal Nos. 8546-8549 of 2024].

_____

Court has held, recording of evidence in a disciplinary proceeding, proposing charges of a major punishment, is mandatory. Reference in this regard may be held to Roop Singh Negi v. Punjab National Bank, (2009) 2 SCC 570 and Nirmala J. Jhala v. State of Gujarat, (2013) 4 SCC 301. Same view was reiterated in State of Uttar Pradesh v. Saroj Kumar Sinha, (2010) 2 SCC 772.

– Hon’ble Justice Sandeep Mehta, Gurmeet Singh v. State of Punjab, [Civil Appeal No. 17529-17530 of 2017] decided on 18.11.2024.

_____

Navin had actually superannuated from SBI on 26.12.2003 on completion of 30 years of service but his service was extended prior thereto on 05.08.2003 from 27.12.2003 to 01.10.2010. Post 01.10.2010 there was no further extension of service. The relationship of master and servant came to be severed on and from 01.10.2010. As has been held by this Court on more than one occasion, a subsisting disciplinary proceeding may be continued post superannuation by creating a legal fiction of continuance of service. But, no disciplinary proceeding can be initiated after a delinquent employee retires from service on attaining age of superannuation or after extended period of service.

– Hon’ble Justice Ujjal Bhuyan, State Bank of India v. Navin Kumar Sinha, [Civil Appeal No. 1279 of 2024] decided on 19.11.2024.