Disciplinary authorities must provide cogent reasons for imposing maximum punishment among multiple available statutory penalties.

The Petitioner, a driver with the Delhi Transport Corporation (DTC), was convicted under Sections 289 and 308/34 of the Indian Penal Code, 1860, on 1 May 2008.

Following a show-cause notice, the DTC dismissed him from service on 14 July 2008 under Regulation 15(2)(vii) of the DRTA (Conditions of Appointment and Services) Regulation, 1952.

Although the High Court later upheld his conviction in 2015, it granted him the benefit of probation under the Probation of Offenders Act, 1958.

The Petitioner challenged his dismissal before the Central Administrative Tribunal (CAT), which dismissed his application (TA 121/2013) on 9 February 2017.

The Petitioner then filed this writ petition, which the High Court limited to the question of the proportionality of the punishment.

1. Whether the punishment of dismissal from service was disproportionate given the Petitioner's 29 years of service and the specific circumstances of the case.

2. Whether the disciplinary authority is required to provide cogent reasons for selecting the maximum penalty among various available options under Regulation 15(2).

The court applied Regulation 15(2) of the DRTA (Conditions of Appointment and Services) Regulation, 1952, which prescribes eight distinct penalties for misconduct, ranging from censure to dismissal.

Paras 9(g) and 10(a)-(c) of the Executive Instructions, which dispense with detailed disciplinary procedures when an employee is convicted by a criminal court.

Discretionary powers to impose punishment must be exercised by providing "cogent reasons," especially when the maximum penalty is invoked.

The court noted that Regulation 15(2) offers a spectrum of eight penalties.

The DTC’s dismissal order dated 14 July 2008 invoked the harshest possible penalty—dismissal—without "adducing any clear reasons" for choosing it over lesser sanctions.

While the court explicitly declined to substitute its own judgment for the DTC's regarding the specific quantum of punishment, it emphasized that the authority must demonstrate application of mind.

The court held that the 29 years of service rendered by the Petitioner was a relevant factor that the competent authority should consider when re-evaluating the proportionality of the sentence.

The court held that while the DTC retains latitude in determining the penalty, it must provide clear reasons for the specific punishment awarded.

The original dismissal order remains in effect until the fresh decision is rendered.