High Courts cannot reappreciate departmental evidence where findings rest on some evidence and procedure was lawful.

The petitioner, a police constable appointed on 16.08.2014, was posted at Police Station Dehat, District Bhind.

A departmental charge-sheet was issued against him on 19.12.2017 alleging, inter alia, association with vehicle thieves, providing them shelter, and indirect involvement in vehicle theft.

After the petitioner submitted his reply, a departmental enquiry was conducted. The Enquiry Officer found Charge No. 1 partly proved and Charge No. 2 not proved.

The Disciplinary Authority disagreed with the Enquiry Officer, issued a dissenting show-cause notice dated 21.09.2018, and considered the petitioner’s reply before dismissing him from service on 11.10.2018.

The petitioner’s departmental appeal was dismissed on 08.03.2019, and his mercy appeal was also rejected on 13.06.2019.

The petitioner challenged these orders under Article 226 of the Constitution, contending that the findings were unsupported by evidence, that call details did not establish collusion, and that the appellate order was non-speaking.

The State maintained that the enquiry complied with the applicable rules, that the petitioner was given adequate opportunity, and that the findings were supported by witness statements and call-detail records.

Whether the findings of misconduct recorded by the Disciplinary Authority were based on no evidence or were so perverse as to warrant interference under Article 226 of the Constitution

Whether the departmental enquiry and the orders of dismissal and appellate rejection violated the principles of natural justice or applicable procedural rules

Whether the High Court could reappreciate the evidence or substitute its own view regarding the petitioner’s guilt and punishment in exercise of writ jurisdiction

The Court applied the limited scope of judicial review over departmental proceedings under Article 226.

Relying principally on State of Karnataka v. N. Gangraj, (2020) 3 SCC 423; State of A.P. v. S. Sree Rama Rao, AIR 1963 SC 1723; B.C. Chaturvedi v. Union of India, (1995) 6 SCC 749; High Court of Bombay v. Shashikant S. Patil, (2000) 1 SCC 416; State Bank of Bikaner & Jaipur v. Nemi Chand Nalwaya, (2011) 4 SCC 584; and Union of India v. P. Gunasekaran, (2015) 2 SCC 610, the Court held that a writ court is not an appellate authority and cannot reappreciate evidence, assess its adequacy or reliability, or substitute its own findings.

Interference is permissible where the enquiry violates natural justice or statutory rules, the decision is arbitrary, mala fide, based on extraneous considerations, or founded on no evidence/perverse findings.

The Court also applied the principle that departmental proceedings are governed by the preponderance-of-probabilities standard rather than proof beyond reasonable doubt, as recognised in State Bank of India v. Ramesh Dinkar Punde, (2006) 7 SCC 212.

The alleged misconduct was considered in the context of Rule 3(1)(i)–(iii) of the Madhya Pradesh Civil Services (Conduct) Rules, 1965, requiring integrity, devotion to duty, and conduct unbecoming of a government servant.

The Court found that the Disciplinary Authority had issued a detailed dissenting note and provided the petitioner an opportunity to respond before imposing punishment; therefore, the requirements of natural justice were satisfied.

The findings were not based on a mere inference from the petitioner’s acquaintance with the accused persons.

The statements of the accused persons allegedly disclosed that stolen motorcycles were supplied to the petitioner, while the call-detail records established repeated telephone contact between the petitioner and those persons.

This constituted relevant evidence capable of supporting the conclusion that the petitioner maintained association with vehicle thieves, provided them shelter, and was indirectly involved in vehicle theft.

Whether that evidence was sufficiently persuasive or whether another inference could be drawn was not for the High Court to determine in judicial review.

Since the disciplinary and appellate authorities had considered the material and recorded reasoned findings, and since the case was not one of no evidence, perversity, or procedural unfairness, the Court declined to reassess the evidence or interfere with the punishment.

It held that the departmental enquiry was conducted in accordance with the applicable rules and principles of natural justice, that the findings of guilt were supported by evidence, and that the dismissal order dated 11.10.2018 and appellate order dated 08.03.2019 did not warrant interference under Article 226.

The writ petition was dismissed, and no reinstatement or consequential benefits were granted.