Tripura High Court Quashes Bank Manager’s Punitive Transfer After KYC Dispute With Labour Secretary
A bank cannot use a transfer to punish an officer without first giving him notice or conducting an inquiry, the Tripura High Court has held while setting aside the transfer of a Chief Manager following a dispute over KYC signatures and a personalised cheque book sought by the State Labour Secretary.
Agartala: The Tripura High Court has directed Tripura Gramin Bank to allow Chief Manager Dr. Pranajit Paul to return to its Agartala branch, finding that his transfer to Poangbari carried adverse findings about his conduct without a prior show-cause notice or inquiry [Dr. Pranajit Paul v. Tripura Gramin Bank & Ors.].
Justice S. Datta Purkayastha allowed the writ petition on November 13, 2026. The Court found that the bank’s own record supported the requirements Paul had insisted upon: the account holder had to sign the KYC documents himself, and a personalised cheque book could not be printed immediately at the branch.
The dispute at the branch
According to Paul’s representation, Labour Secretary Tapas Roy visited the branch on August 26 seeking a personalised cheque book for an account held jointly with his adult son. Paul said he entered the request in the banking system and explained that printing and dispatch would take time. He also said the son’s KYC papers needed the son’s signature, rather than the father’s.
Paul denied misbehaving and said he had offered to send bank staff to obtain the son’s signature. The bank, however, alleged indifferent behaviour and poor customer service. Its September 9 transfer order referred to lapses in courtesy, promptness and professionalism, and directed him to join Poangbari immediately without joining time.
The bank defended its general power to transfer staff and argued that Paul’s conduct had displeased the customer and damaged its reputation. It also pointed to apologies offered by bank officials and a departmental appeal remedy. A show-cause notice proposing disciplinary action was issued on September 14, after the transfer.
Bank’s own records supported the requirements
In paragraph 13, the Court examined a confidential visit report recording a bank delegation’s meeting with the Secretary on August 27. The delegation had explained that KYC documents required the concerned customer’s signature and that personalised cheque books were processed centrally in Jalandhar, with delivery taking up to seven working days.
The Court therefore found that an instant personalised cheque book and the father signing for his adult son were not permissible or feasible under the applicable bank norms. It held that the transfer was punitive because it cast aspersions on Paul’s efficiency, behaviour and skill without first giving him notice or holding an inquiry.
Paragraph 14 identified a further defect: neither the transfer order nor the visit report specified the alleged misbehaviour. Even the later show-cause notice made a general allegation of indifferent attitude and poor service without explaining what Paul had actually done wrong.
Transfer power cannot substitute for disciplinary process
Applying Somesh Tiwari v. Union of India, (2009) 2 SCC 592, the Court distinguished an ordinary administrative transfer from one imposed in lieu of punishment. In paragraph 15, it found interference warranted because the order was arbitrary, contained punitive findings without sufficient reason, and breached natural justice. No fault or deficiency on Paul’s part had been established.
The Court also rejected the objection based on the unexhausted departmental appeal. In paragraph 16, it reiterated that an alternative remedy does not invariably prevent a High Court from exercising jurisdiction under Article 226; the rule requires judicial restraint rather than an absolute refusal to hear the case.
The directions
Under paragraph 17, the September 9 transfer order stands quashed. The bank must permit Paul to join the Agartala branch within seven days of the judgment and regularise his unauthorised absence with wages for that period upon submission of his leave application in due course. The writ petition was disposed of, any interim order vacated, and pending applications disposed of.
The ruling turns on the punitive contents of this transfer and the absence of fair procedure. It does not remove the bank’s ordinary administrative power to transfer employees.
Case: Dr. Pranajit Paul v. Tripura Gramin Bank & Ors.
Case Number: WP(C) No. 721 of 2026
Citation: 2026:THC:1491
Court and Bench: High Court of Tripura, Agartala; Justice S. Datta Purkayastha
Decision Date: November 13, 2026
Outcome: Writ petition allowed; transfer quashed, with directions for return to Agartala branch and regularisation of absence with wages subject to submission of a leave application.
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