For three-year non-cumulative increment withholding, Rule 11 does not mandate a departmental inquiry.

The applicant, a Technician-I (Electrical) employed with the North Central Railway, was served with a charge memorandum dated 13 October 2025 alleging that he had incited co-workers against the administration, obstructed work at the Loco Trip Shed, and misbehaved with supervisors, thereby violating Rule 3(1)(ii) and (iii) of the Railway Services (Conduct) Rules, 1966.

He submitted his reply on 3 November 2025 and relied, inter alia, on a declaration signed by 28 co-workers.

The Disciplinary Authority, after considering his representation, imposed the penalty of withholding three annual increments without cumulative effect by order dated 17 November 2025.

The applicant’s departmental appeal dated 6 December 2025 was rejected on 9 January 2026, and his revision petition was rejected on 22 May 2026.

He challenged the charge memorandum, penalty order, appellate order and revisional order before the Tribunal, principally alleging non-compliance with the procedure applicable to minor penalties.

Whether the disciplinary authorities violated the procedure prescribed under Rule 11 of the Railway Servants (Discipline and Appeal) Rules, 1968 while imposing the minor penalty of withholding three increments without cumulative effect

Whether the penalty and the orders affirming it were liable to be interfered with on the ground that the findings were unsupported or that the punishment was disproportionate

The Tribunal applied Rule 11(1) of the Railway Servants (Discipline and Appeal) Rules, 1968, which requires that, before imposing a minor penalty, the employee must be informed in writing of the imputations and given a reasonable opportunity to submit a representation; the authority must consider the representation, hold an inquiry where it considers one necessary, and record findings on the imputations.

Under Rule 11(2), a formal inquiry is mandatory where withholding increments is likely to adversely affect pension or provident-fund benefits, exceeds three years, or is imposed with cumulative effect.

The Tribunal further relied on the limited scope of judicial review in disciplinary matters: courts and tribunals review the legality and procedural fairness of the decision rather than reappreciate evidence.

Citing S.R. Tewari v. Union of India, 2013 (7) SCALE 417, it held that interference with punishment is justified only in exceptional cases, particularly where the punishment is shocking to the conscience of the court and the authority’s decision suffers from legal or procedural infirmity.

The Tribunal found that the applicant had been supplied with the allegations and afforded an opportunity to submit his reply before the penalty was imposed.

The Disciplinary Authority considered his representation and concluded that the allegations were established, while the appellate and revisional authorities independently considered and affirmed the penalty.

Since the penalty involved withholding increments for three years without cumulative effect, and the record did not show that it adversely affected pensionary or provident-fund benefits, the Tribunal held that Rule 11(2) did not mandate a formal inquiry; Rule 11(1) had been complied with.

Applying the restricted standard of judicial review, the Tribunal declined to reassess the factual findings or substitute its own view for that of the disciplinary authorities, finding no jurisdictional error or procedural irregularity.

The challenge to the charge memorandum, penalty order, appellate order and revisional order was therefore rejected.

The Original Application was dismissed, and all pending miscellaneous applications, if any, were disposed of.