When Charges Are Grave, Authorities Must Exercise Heightened Caution And Evidentiary Scrutiny In Disciplinary Proceedings: Supreme Court

The Court observed that conclusions affecting civil consequences, particularly dismissal from service, must be grounded in reliable verification, and speculative findings cannot sustain punitive action.

The Court was hearing an appeal challenging the dismissal of an employee following a departmental inquiry into allegations of unauthorised absence and submission of a fabricated medical certificate.

A Bench of Justice K.V. Viswanathan and Justice Vipul M. Pancholi emphasised that the seriousness of a charge determines the degree of evidentiary scrutiny required. The Court observed that “when charges are grave, the caution and circumspection that should be exercised by the authorities should be greater”.

Background

The appellant, an attender employed in a district Court since 1998, remained absent for a few days in 2017, citing illness and subsequently produced a handwritten medical certificate purportedly issued by a local doctor. During departmental verification, the doctor stated that the certificate did not bear his signature, though he acknowledged that the appellant had consulted him and received treatment.

A disciplinary inquiry was initiated, charging the appellant with unauthorised absence and fabrication of the medical certificate. The inquiry officer relied primarily on the doctor’s denial of authorship and concluded that the certificate was fabricated. The disciplinary authority dismissed the appellant from service, a decision upheld in departmental appeal and by the High Court.

Court’s Observations

The Supreme Court examined whether the disciplinary finding was supported by credible evidence. While reiterating that judicial review does not extend to reappreciation of evidence, the Bench held that interference is warranted where findings are perverse or unsupported.

The Court noted that the certificate was entirely handwritten, bore the doctor’s letterhead and stamp, and that the doctor admitted treating the appellant. Despite the seriousness of the allegation, which effectively amounted to forgery, the inquiry authority did not undertake comparative verification of signatures or seek expert examination of the disputed writing.

The Bench held that when charges are grave, the standard of scrutiny must correspondingly rise. Failure to conduct basic evidentiary verification in such circumstances rendered the conclusion speculative and legally unsustainable.

The Bench referenced the Apex Court’s ruling in Sawai Singh vs. State of Rajasthan (1986), in which it was held: “in a departmental enquiry entailing consequences like loss of job which nowadays means loss of livelihood, there must be fair play in action; in respect of an order involving adverse or penal consequences against an employee, there must be investigations to the charges consistent with the requirement of the situation in accordance with the principles of natural justice insofar as these are applicable in a particular situation.”

The Court also clarified that reliance on an earlier service penalty was irrelevant once the present charge itself was not established, as disciplinary action must stand solely on the strength of evidence relating to the specific misconduct alleged.

Conclusion

Holding that the charge of fabrication was not proved on reliable material, the Supreme Court set aside the disciplinary findings, the dismissal order, and the judgments affirming them. The appellant was directed to be reinstated with full consequential benefits, including arrears of salary.

Cause Title: K. Rajaiah v. The High Court for the State of Telangana (Neutral Citation: 2026 INSC 142)

Appearances

Appellant: Senior Advocate Pratap Narayan Sanghi, with Avadesh Narayan Sanghi and Yashaswi Sk Chocksey, Advocates; Krishna Kumar Singh, AOR.

Respondent: Sindoora VNL, AOR, with Thithiksha Padmam, Advocate.

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