Supreme Court clarifies courts cannot re-appreciate evidence once a fair domestic enquiry is upheld

In The General Manager (P), Canara Bank v. Ganganarasimhaiah (Civil Appeal No. 11461 of 2025), dated 9 September 2025 the Supreme Court examined the scope of judicial review over disciplinary proceedings under the Industrial Disputes Act, 1947.

The respondent, a sub-staff employee of Canara Bank, had been compulsorily retired following charges of serious irregularities, including unauthorized entries in bank accounts, sanction of loans to close relatives without approval, and tampering with official records. While a domestic enquiry held the charges proved, the Central Government Industrial Tribunal (2019) and the Karnataka High Court (2022) set aside the punishment, directing reinstatement with continuity of service but without back wages.

The Supreme Court reversed these findings, holding that both the Tribunal and the High Court exceeded their jurisdiction under Section 11A of the Industrial Disputes Act by re-appreciating evidence and applying a standard akin to proof “beyond reasonable doubt.” The Court reiterated that disciplinary enquiries are governed by the principle of preponderance of probabilities rather than strict evidentiary standards. It stressed that once a fair enquiry has been upheld, judicial bodies cannot substitute their own factual assessments or sit in appeal over the findings of the disciplinary authority.

This judgment reaffirms the limited scope of judicial interference in employer disciplinary actions and highlights that proportionality of punishment must be assessed with due regard to the gravity of misconduct. For employers, the ruling provides clarity that as long as disciplinary proceedings comply with natural justice and evidentiary standards appropriate to service law, subsequent judicial forums cannot casually overturn punishment orders.