Courts cannot reappreciate disciplinary evidence where findings are supported by some evidence.

The applicant, a Postal Assistant appointed in 1999, officiated as Inspector of Posts, Gudalur Sub-Division, during the relevant period.

He supervised the selection and appointment process for the post of GDS Mail Deliverer, Nellakotta S.O., and an appointment order was issued in favour of Smt. A.R. Aysha Thabasum, stated to be the most meritorious candidate.

Following a complaint, the applicant was issued a charge memo dated 19 February 2015 under Rule 14 of the CCS (CCA) Rules, 1965.

A regular departmental inquiry was conducted in which the applicant participated with the assistance of a Defence Assistant.

The Inquiry Officer held all three charges proved. The Disciplinary Authority imposed the penalty of removal from service by order dated 24 August 2016; the appeal and revision were rejected on 16/22 November 2016 and 4 July 2017 respectively.

Whether the departmental inquiry and the findings that the charges were proved were vitiated by reliance on preliminary-inquiry statements, non-examination of the Preliminary Inquiry Officer, violation of natural justice, or absence of sufficient evidence.

Whether the Disciplinary, Appellate, and Revisional Authorities independently considered the evidence and the applicant’s defence, or mechanically accepted the Inquiry Officer’s findings.

Whether the penalty of removal from service was shockingly disproportionate to the proved misconduct.

Whether the Tribunal could re-appreciate the evidence or substitute its own view for that of the departmental authorities in judicial review.

The Tribunal applied Rule 14 of the CCS (CCA) Rules, 1965, governing major-penalty departmental inquiries, and Rule 11 concerning the penalties that may be imposed.

The applicant was also found to have violated Rules 3(1)(i) and 3(1)(ii) of the CCS (Conduct) Rules, 1964, requiring absolute integrity and devotion to duty.

The applicable standard in disciplinary proceedings is the preponderance of probabilities, not proof beyond reasonable doubt.

Judicial review is limited to examining whether the inquiry was conducted by a competent authority in accordance with the prescribed procedure and principles of natural justice, and whether the findings are supported by some evidence; courts and tribunals do not act as appellate authorities to re-appreciate evidence.

Relying on SBI v. K.S. Viswanath, decided 20 May 2022, and The General Manager (P), Canara Bank v. Ganganarashimhaiahee, order dated 9 September 2025, the Tribunal reiterated that interference is justified only where findings are perverse, based on no evidence, or the proceedings suffer from procedural or natural-justice violations.

The Tribunal found that the applicant had received a full opportunity to defend himself in the Rule 14 inquiry and had participated with the assistance of a Defence Assistant.

The Inquiry Officer considered the oral and documentary materials and found all three charges proved.

In relation to the bribery charge, the record included the applicant’s alleged admission during the preliminary inquiry and the unexplained deposit of Rs. 85,000 under a UCR receipt, along with evidence concerning the irregular rejection and consideration of applications in the GDS selection process.

The Tribunal held that the non-examination of the Preliminary Inquiry Officer did not invalidate the inquiry, particularly as the findings were not based solely on that officer’s statements and other evidence was available.

Since the evidence furnished a reasonable basis for the findings, the Tribunal declined to re-weigh the evidence or assess the credibility of witnesses afresh.

Given that the misconduct involved demand and acceptance of illegal gratification and directly affected the applicant’s integrity as a public servant, the Tribunal held that removal from service could not be regarded as shockingly disproportionate.

It held that the departmental inquiry complied with the prescribed procedure, that the findings of guilt were supported by evidence, and that the Disciplinary, Appellate, and Revisional Authorities had duly considered the applicant’s submissions.

The proved misconduct was serious and related directly to the applicant’s integrity; therefore, the penalty of removal from service was not disproportionate.

The Original Application was accordingly dismissed as devoid of merits, with the parties directed to bear their own costs.