Courts cannot reappreciate disciplinary findings supported by some evidence.

On 27 July 1997, the Karnataka Express collided with a stationary train near Faridabad after failing to stop at a red signal, causing 12 deaths and injuries to more than 50 passengers.

The petitioner, then the assistant driver, was charged with failing to act promptly to stop the train.

He was dismissed from service in 2004.

Following earlier proceedings before the Central Administrative Tribunal and the High Court, the disciplinary inquiry was conducted afresh; the Inquiry Officer found the charges proved, and the petitioner was again removed from service in 2013.

His appeal was rejected, and the Tribunal dismissed his challenge in 2019.

The petitioner then sought judicial review under Article 226, relying, among other things, on his acquittal in related criminal proceedings and disputing the factual findings against him.

1. Whether the Tribunal’s decision upholding the disciplinary findings and removal order disclosed a ground for interference under Article 226, including perversity, absence of evidence, or procedural unfairness

2. Whether the petitioner’s acquittal in the criminal proceedings required his exoneration in the disciplinary proceedings

3. Whether removal from service was disproportionate to the misconduct found proved

Under Article 226, judicial review of disciplinary proceedings is supervisory, not appellate.

Applying Union of India v. P. Gunasekaran, B.C. Chaturvedi v. Union of India and related authorities, the Court stated that it may review whether the inquiry was conducted by a competent authority and in accordance with prescribed procedure and natural justice, and whether findings rest on some evidence; it may also intervene for perversity, arbitrariness, or other recognised legal defects.

It may not reappreciate evidence, assess its adequacy or reliability, or substitute its factual conclusion where some evidence supports the finding.

Disciplinary guilt is determined on the balance of probabilities, a standard distinct from proof beyond reasonable doubt; acquittal in a criminal case does not, by itself, require exoneration in disciplinary proceedings.

A punishment may be reviewed if it is shockingly disproportionate, but ordinarily the disciplinary authority should reconsider the penalty.

The Inquiry Officer considered the petitioner’s account that he called out the danger signal and applied the emergency brake, as well as his explanation that an obstruction prevented the brake from operating.

The Officer rejected those explanations and found that the petitioner had failed to act promptly and make an adequate effort to stop the train.

The High Court held that these were factual findings supported by the inquiry material, and that assessing the petitioner’s competing account—including his reliance on injuries and a reported jerk—would amount to impermissible reappreciation of evidence.

The Disciplinary Authority had also considered the petitioner’s representation and the inquiry findings.

The criminal acquittal did not displace those findings because the disciplinary inquiry applied a different standard of proof.

Given the grave consequences of the misconduct, the Court found no basis to regard dismissal as disproportionate.

It found no reviewable defect in the disciplinary findings, held that the criminal acquittal did not entitle him to disciplinary exoneration, and rejected the proportionality challenge.

The writ petition was dismissed, with no order as to costs.