A disciplinary penalty imposed after the court-fixed deadline, without extension, is unsustainable.

The Bank initially removed the petitioner from service following disciplinary proceedings.

In an earlier writ petition, the High Court set aside the penalty for a procedural defect and permitted the Bank to proceed afresh, directing it to complete the proceedings within six months of receiving the judgment; otherwise, the proceedings would stand terminated.

The Bank received the judgment by 31 December 2024, but did not pass its final penalty order until 8 August 2025.

Although it had sought an extension of time, no extension was granted.

The petitioner challenged the later penalty order.

1. Whether the Bank could validly impose a penalty after the six-month period fixed by the Court had expired, in the absence of an extension of time.

2. Whether the Bank established that the petitioner was responsible for delay sufficient to avoid the consequence specified in the earlier order.

The earlier judgment in the petitioner’s case expressly required the Bank to complete the disciplinary proceedings within six months of receipt, failing which the proceedings would stand terminated.

In State of Uttar Pradesh v. Ram Prakash Singh, 2025 (2) PLJR (SC) 331, the Supreme Court held that, where an inquiry must be completed within a time stipulated by a court or tribunal, no valid punishment may be imposed after that period without an extension of time.

The proceedings were conducted under Regulation 6 of the Punjab National Bank Officer Employees’ (Discipline & Appeal) Regulations, 1977.

The Bank received the earlier judgment on or before 31 December 2024, so the six-month period expired by 30 June 2025.

The final penalty was imposed on 8 August 2025, after that deadline.

The Bank’s application seeking an extension did not extend the deadline because no order granting an extension was made.

Nor did the Bank substantiate its assertion that the petitioner caused the delay with supporting material.

Applying the express condition in the earlier judgment and the rule in Ram Prakash Singh, the Court held the post-deadline penalty unsustainable.

and allowed the writ application with all consequential benefits.