The Supreme Court restored SBI’s punishment against a messenger found guilty of bribery, ruling that disciplinary authorities need not give detailed reasons if they agree with the inquiry officer’s findings. This strengthens SBI’s stand on strict anti-corruption measures.
The Supreme Court of India has given a major relief to the State Bank of India (SBI) by restoring the punishment imposed on its employee who was found guilty of taking bribes. The Court ruled that when a Disciplinary Authority of SBI agrees with the findings of an Inquiry Officer, it does not need to write a detailed order while imposing punishment.
A bench of Justice Rajesh Bindal and Justice Manmohan allowed SBI’s appeal against the Patna High Court, which had earlier quashed the punishment. The Supreme Court held that the High Court had wrongly interfered with the disciplinary process and reaffirmed SBI’s decision to remove the employee from service.
The case involved Ramadhar Sao, who joined SBI as a messenger in 1997. In 2008, complaints were filed against him for taking bribes to help in sanctioning loans. After a departmental inquiry, he was charged on January 5, 2010, for acting as a “middleman,” taking “illegal gratification,” and being absent from duty without permission. The Inquiry Officer found him guilty in a report dated October 4, 2010, and the Disciplinary Authority dismissed him from service on January 8, 2011.
On appeal, SBI’s Appellate Authority took a “compassionate view” and reduced the punishment to removal from service with superannuation benefits on December 7, 2012. However, Sao challenged this before the Patna High Court, where a Single Judge quashed the punishment. SBI’s intra-court appeal also failed, forcing the Bank to move the Supreme Court.
SBI argued before the Supreme Court that the High Court had gone beyond its limited powers of judicial review. The Bank stressed that the inquiry was fair, all principles of natural justice were followed, and that courts cannot act like appellate authorities in such matters. On the other hand, Sao’s counsel said he was only a low-level employee and was being made a scapegoat for irregularities committed by higher officials.
The Supreme Court sided with SBI and said that the High Court had no reason to interfere. Relying on earlier rulings, the Court quoted:
“it is well settled that if the disciplinary authority accepts the findings recorded by the enquiry officer and passes an order, no detailed reasons are required to be recorded in the order imposing punishment. The punishment is imposed based on the findings recorded in the enquiry report, as such, no further elaborate reasons are required to be given by the disciplinary authority.”
The bench also referred to SBI v. Ajai Kumar Srivastava (2021) to reiterate that judicial review has a limited scope and High Courts cannot re-evaluate evidence like an appellate court.
The Supreme Court rejected the Patna High Court’s view that the findings were based on “conjuncture and surmises.” It highlighted the testimony of five loanees who
“categorically deposed that they had paid money to the respondents.”
The Court also took note of Sao’s own words before the Disciplinary Authority, where he admitted indirectly, saying,
“Knowingly or unknowingly whatever mistake I have made, please forgive me.”
Finally, the Supreme Court allowed SBI’s appeal and restored the Appellate Authority’s order of December 7, 2012, which imposed the penalty of removal from service with superannuation benefits.
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This ruling is a big vindication for SBI’s disciplinary process, reinforcing that banks can act firmly against corruption among employees, and courts cannot interfere unless there is a clear violation of procedure.
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