Judicial review evaluates the decision-making process in disciplinary actions, not the merits of the findings.

The Petitioner, a Sub-Inspector, was subjected to a departmental enquiry for failing to comply with a judicial order from the Judicial Magistrate First Class, Jaijaipur, to submit a final report in a criminal case.

During the enquiry, the Petitioner filed applications for the supply of specific documents and the appointment of a Defence Assistant, which she claimed were not granted.

The enquiry officer found the charges proved, leading to an initial penalty of pay scale deduction.

On appeal, the Director General of Police (DGP) modified the penalty to the stoppage of one increment for one year.

After her revision petitions were dismissed, the Petitioner challenged the punishment, appellate, and revisional orders before the High Court, alleging procedural irregularities and violations of the Chhattisgarh Civil Services (Classification, Control & Appeal) Rules, 1966.

1. Whether the non-supply of documents and the alleged denial of a Defence Assistant constituted a violation of the principles of natural justice and Rule 14 of the Rules, 1966.

2. Whether the enquiry officer failed to comply with Rule 14(19) regarding the submission of written briefs and Rule 18 regarding common proceedings.

3. Whether the High Court can interfere with the concurrent findings of the disciplinary, appellate, and revisional authorities under the scope of judicial review.

The court applied the Chhattisgarh Civil Services (Classification, Control & Appeal) Rules, 1966, specifically Rule 14 (procedure for imposing penalties), Rule 14(8) (appointment of Defence Assistant), Rule 14(19) (submission of written briefs), and Rule 18 (common proceedings for multiple delinquent employees).

It further relied on the Supreme Court precedents in Punjab National Bank v. M.L. Kalra (2023) and Indian Oil Corporation v. Ajit Kumar Singh (2023), which establish that judicial review of disciplinary actions is limited to correcting legal or procedural errors and does not extend to reappreciating evidence or merits unless the findings are perverse or based on no evidence.

The Court found that the documents requested by the Petitioner (FIR, complaints, and revenue records) were not in the possession of the enquiry officer but were public records obtainable from the court or revenue authorities; thus, no procedural lapse occurred in their non-supply.

Regarding the Defence Assistant, the Court noted that the Petitioner failed to raise this ground before the appellate or revisional authorities and failed to demonstrate any actual prejudice caused by the lack of such assistance.

The Court dismissed the argument regarding Rule 14(19), clarifying that the rule allows a delinquent official to submit a written brief, which the Petitioner failed to do, rather than mandating the enquiry officer to provide one.

The Court confirmed that the Inspector General of Police had formally authorized common proceedings as per Rule 18.

Applying the "limited scope of judicial review" doctrine, the Court held it could not act as an appellate authority to re-examine the facts when the decision-making process was fair and consistent with statutory rules.

The Court affirmed the concurrent findings and orders of the disciplinary, appellate, and revisional authorities, concluding that no case for interference was made out.

Relief for refund of deducted amounts and compensation was denied.