Courts will not re-appreciate evidence in departmental inquiries under Article 226 if due process was followed.

The appellant was issued a charge-sheet in 2012 by Indian Oil Corporation Limited regarding allegations of dereliction of duty

Following an inquiry concluded in 2014, two charges were proven, and the Disciplinary Authority imposed the punishment of "censure"

The appellant’s internal appeal was dismissed

Initially, the appellant filed a writ petition seeking both the opening of a "sealed cover" for promotion and a challenge to the penalty; however, he restricted that petition to the sealed cover issue while reserving liberty to challenge the penalty separately

Consequently, he filed a subsequent petition challenging the censure, seeking promotion from Grade-B to Grade-C, arrears of pay, and Rs. 10 crores in damages

The learned Single Judge dismissed the challenge to the penalty, noting that censure did not harm future prospects and relegated the claim for damages to a Civil Court

1. Whether the High Court, under Article 226 of the Constitution of India, can interfere with a departmental inquiry and the resulting penalty of censure when the delinquent participated fully in the proceedings.

2. Whether the prayer for promotion and arrears of pay survived after the respondent granted retrospective promotion and paid the alleged dues during the pendency of proceedings.

The court applied the established principle of judicial review under Article 226 of the Constitution of India, which dictates that in departmental proceedings, the High Court does not sit as a Court of Appeal and will not re-appreciate evidence if the inquiry followed due process

It further relied on the doctrine that if an administrative penalty (like censure) does not adversely affect future career prospects, and the inquiry was conducted fairly, the scope of interference is extremely limited

The Court observed that the appellant had participated fully in the disciplinary inquiry and all his contentions were considered by the Inquiry Officer and the Disciplinary Authority

Since the inquiry report was accepted and a mild penalty of censure was imposed, the Court found no procedural or legal infirmity

Regarding the prayers for promotion and arrears, the Court noted that the respondent had already granted the appellant retrospective promotion and settled the calculated arrears; therefore, these grievances were largely redressed

The Court emphasized that it cannot act as a secondary disciplinary body to re-evaluate the merits of the evidence when the procedural requirements of natural justice were satisfied

The Court clarified that while the current appeal is dismissed, the appellant remains at liberty to initiate separate appropriate proceedings if he is aggrieved by the specific computation of arrears or any technical aspect of his retrospective promotion

Relief for damages was maintained as a matter for the Civil Court as determined by the Single Judge