Writ courts cannot reappreciate disciplinary evidence absent perversity or breach of natural justice.

The petitioner, an In-charge of the Police Chowki at Government Hospital, Burhanpur, faced disciplinary proceedings on the charge that he was under the influence of alcohol while on duty during the night of 29–30 November 2019.

Following an enquiry, the disciplinary authority imposed stoppage of three annual increments with cumulative effect.

On appeal, the penalty was reduced to stoppage of one annual increment with cumulative effect.

The petitioner challenged both orders, alleging, among other things, a fabricated complaint, lack of mandatory laboratory testing, prejudice in the enquiry, and breach of natural justice.

The State maintained that the enquiry was fair and the findings were supported by evidence.

Whether the disciplinary and appellate orders warranted interference under Article 226 on grounds of procedural irregularity, breach of natural justice, or findings unsupported by evidence.

Whether the High Court could reappreciate the evidence adduced in the departmental enquiry.

Under Article 226, a writ court does not act as an appellate authority to reweigh or reappreciate evidence in a departmental enquiry.

Judicial review is confined to the decision-making process, including whether the enquiry was conducted by a competent authority, complied with natural justice, and resulted in findings supported by “some evidence.”

Relying on Deputy General Manager (Appellate Authority) and Others v. Ajai Kumar Srivastava, (2021) 2 SCC 612, the Court stated that interference is warranted where findings are perverse or unsupported by evidence, or where the enquiry flagrantly violates statutory rules or natural justice; the adequacy, reliability, and sufficiency of evidence are for the departmental authorities.

The Court found that the petitioner had received a charge sheet, submitted a reply, and participated in the enquiry, where witnesses were examined and cross-examined in his presence.

The authorities relied on the material on record, including the preliminary report and medical observations, in finding misconduct.

The appellate authority had independently considered the matter and reduced the penalty.

Applying the limited scope of review under Article 226, the Court declined to reassess the evidence and found no procedural irregularity, breach of natural justice, or perversity warranting intervention.

The writ petition was dismissed as devoid of merit, leaving in place the appellate order imposing stoppage of one annual increment with cumulative effect.