After 28-year legal battle, Delhi High Court awards bank manager ₹50,000 for foiling armed robbery and adds ₹2 lakh litigation costs

The petitioner, a Senior Manager of Punjab & Sind Bank, was posted at the Roshan Pura, Najafgarh Branch, on 28 December 1998 when five armed robbers entered the bank and threatened its staff and customers.

While two robbers pointed guns at the petitioner, he activated the emergency alarm and subsequently obstructed the exit door, causing the cash bag to fall and the currency to scatter.

The robbers escaped with only ₹75,000, thereby substantially preventing the robbery.

The petitioner was recommended by senior bank officers and the Punjab & Sind Bank Officers’ Union for a reward and out-of-turn promotion under the Government of India’s Guidelines dated 14 October 1991.

The Bank rejected his claim on the ground that he had not actively resisted the robbery and had merely performed his official duty.

The petitioner thereafter filed a writ petition under Article 226 seeking compensation, reward, and out-of-turn promotion under the Guidelines.

Whether the petitioner’s conduct in activating the emergency alarm and obstructing the robbers, despite being under threat of firearms, constituted “actively resisting” a bank robbery under Clause (vi) of the Guidelines dated 14 October 1991?

Whether the respondents were justified in rejecting the petitioner’s claim for the benefits contemplated under the Guidelines on the ground that he had merely performed his official duty?

Whether the petitioner was entitled to monetary relief and costs for the respondents’ failure to acknowledge and implement the applicable Guidelines?

The Court exercised jurisdiction under Article 226 of the Constitution of India to review the respondents’ rejection of the petitioner’s claim.

It applied the Government of India, Department of Economic Affairs (Banking Division), Guidelines dated 14 October 1991.

Clause (vi) provides for a cash reward of up to ₹50,000 to bank employees, customers, or members of the public who actively resist bank robberies or terrorist attacks; it also permits an out-of-turn promotion for eligible bank employees and, where the employee is not eligible for such promotion, three permanent advance increments.

Clause (vii) provides for treatment expenses for injuries, while Clause (viii) clarifies that the cash reward is in addition to any compensation otherwise available under law.

The governing principle applied was that conduct involving conscious and courageous resistance to an armed robbery, beyond routine discharge of employment duties, falls within the expression “actively resist” in Clause (vi).

The Court held that the petitioner’s conduct could not be reduced to the routine performance of his duties.

Unlike the guards and other bank officials who surrendered or complied with the robbers’ demands, the petitioner activated the alarm while two armed robbers had guns pointed at him and then attempted to block their escape.

These actions materially disrupted the robbery and reduced the loss from approximately ₹40,00,000 to ₹75,000.

Since Clause (vi) expressly recognizes active resistance to bank robbery as warranting a cash reward, the Bank’s assertion that the petitioner had only done what his duty required was held to be an impermissible trivialisation of his exceptional courage.

The respondents’ failure to apply their own Guidelines was therefore unjustified, particularly when the petitioner’s conduct had been supported by recommendations from senior officers and the employees’ union.

The Court held that the petitioner had actively resisted the armed robbery within the meaning of Clause (vi) of the 14 October 1991 Guidelines.

The Court awarded him ₹50,000 as compensation, together with 12% annual compound interest from 28 December 1998 until actual disbursement.

The respondents were also directed to pay ₹2,00,000 as litigation costs, with payment to be made within three months of the judgment.

The judgment did not itself grant an out-of-turn promotion; the operative relief was the monetary reward/compensation and costs.