A disciplinary penalty cannot stand on a vague charge lacking particulars of the alleged misconduct.

Disciplinary charges were issued against the third respondent, then Principal-cum-Associate Professor, alleging irregular purchases and failure to act against teaching and non-teaching staff who were unauthorisedly absent.

The Enquiry Officer found the purchase-related charge unproved but the charge concerning staff absence proved.

The Disciplinary Authority imposed a penalty of withholding four increments with cumulative effect.

The Karnataka State Administrative Tribunal set the penalty aside, finding the enquiry findings perverse; the Registrar, Karnataka Lokayukta, challenged that order before the High Court.

Whether the Tribunal was justified in setting aside the penalty on the ground that the finding on the charge concerning unauthorised staff absence was perverse and unsupported by adequate particulars.

Whether the High Court, exercising judicial review over disciplinary proceedings, should interfere with the Tribunal’s decision.

Under the Karnataka Civil Services (Classification, Control and Appeal) Rules, 1957, the Disciplinary Authority may impose a penalty in disciplinary proceedings.

The Court stated that judicial review in such matters is limited: it does not sit as an appellate authority to reappreciate evidence, but may examine whether the enquiry complied with the principles of natural justice, whether the finding is based on no evidence, and whether the penalty is proportionate to the charges.

A disciplinary charge must provide sufficient particulars to enable the employee to understand and answer the allegation; a vague charge cannot properly sustain an adverse finding.

The first part of the charge, concerning purchases, was found unproved and did not form the basis of the penalty under review.

The second part alleged generally that the respondent had failed to act against absent staff, but identified neither the staff members concerned nor the relevant periods of absence.

The Court held that this lack of particulars made the charge vague and supported the Tribunal’s conclusion that the Enquiry Officer’s finding was perverse and not in accordance with the material on record.

The Tribunal’s decision therefore did not warrant interference under the limited scope of judicial review.

It rejected the writ petition, leaving the Tribunal’s order setting aside the penalty undisturbed.