Writ courts cannot reappreciate departmental evidence absent perversity, jurisdictional error, or natural-justice violation.

The petitioner, a Patwari, was subjected to disciplinary proceedings pursuant to a charge-sheet dated 28.03.2014 alleging dereliction of duty in failing to conduct a survey and assess crop loss caused by hailstorm pursuant to an order dated 28.02.2014.

She submitted her reply and relied on her illness and subsequent medical documents.

The Enquiry Officer, by report dated 23.07.2015, found the charges proved, and the disciplinary authority imposed the penalty of withholding one increment with cumulative effect by order dated 07.12.2015.

The petitioner’s appeal was initially dismissed on the ground of delay.

In Writ Petition No. 21425 of 2018, the matter was remanded to the appellate authority for consideration on merits.

On remand, the appeal was dismissed by order dated 11.03.2019.

The petitioner consequently invoked Article 226 of the Constitution seeking quashing of both orders, full wages for the suspension period, and consequential benefits.

Whether the disciplinary and appellate orders finding the petitioner guilty of dereliction of duty were perverse, arbitrary, or unsupported by the material on record?

Whether the High Court, while exercising judicial review under Article 226, could reappreciate the evidence and substitute its own assessment for that of the departmental authorities?

Whether the penalty of withholding one increment with cumulative effect warranted interference as unjustified, disproportionate, or without jurisdiction?

The Court applied the principles governing judicial review of departmental disciplinary proceedings under Article 226 of the Constitution.

It held that the High Court does not act as an appellate authority and cannot reappreciate evidence; interference is confined to errors of law, procedural irregularity, violation of natural justice, perversity, manifest miscarriage of justice, lack of jurisdiction, or an absolutely unjustified or disproportionate penalty.

The Court relied on Government of Andhra Pradesh v. Mohd. Nasrullah Khan, (2006) 2 SCC 373, which establishes that judicial review is not equivalent to appellate adjudication on the merits and that the High Court cannot reassess evidence merely because another view is possible.

The Court found that the petitioner was present when the survey team was constituted on 28.02.2014 and was assigned the duty of assessing hailstorm-related crop loss.

Her defence relied principally on absence and medical documents relating to the period beginning 01.03.2014, whereas the alleged failure to perform the assigned duty occurred on 28.02.2014.

The Enquiry Officer had considered the departmental evidence and the petitioner’s documents before recording a finding of guilt, and the appellate authority independently considered the petitioner’s contentions and documents.

The Court further noted that the petitioner had not expressly denied the charges in her reply but had offered a different explanation.

Since no perversity, jurisdictional error, violation of natural justice, or manifest disproportionality was established, the Court declined to reassess the evidence or interfere with the departmental findings under Article 226.

It held that the charges of dereliction of duty were supported by the enquiry material, that the disciplinary and appellate authorities had properly exercised their jurisdiction, and that the penalty of withholding one increment with cumulative effect did not warrant interference.

The writ petition was accordingly dismissed as meritless, and no relief regarding quashing of the orders, full suspension wages, or consequential benefits was granted.