Supreme Court Reaffirms Limited Judicial Review in Disciplinary Proceedings—High Court Cannot Reappreciate Evidence or Dilute Proven Misappropriation

Case Name: Union of India & Ors. v. Indraj
Citation: Civil Appeal No. 13183 of 2025; 2025 INSC 1313
Date of Judgment/Order: 13 November 2025
Bench: Hon’ble Mr. Justice Rajesh Bindal & Hon’ble Mr. Justice Manmohan

Held: The Supreme Court held that the High Court exceeded its jurisdiction in judicial review by reassessing evidence and questioning the respondent’s admissions despite a duly conducted inquiry that clearly established misappropriation of public funds by a Branch Postmaster. The Court clarified that once the inquiry is fair, evidence is cogent, and charges are proved—including the respondent’s own written admission and subsequent deposit of the embezzled amount—the High Court cannot substitute its own factual findings or dilute the penalty. Misappropriation of depositor funds strikes at the root of public trust, and mere repayment after being caught does not absolve the misconduct.

Summary: The respondent, a Gramin Dak Sevak/Branch Postmaster since 1998, was charged with misappropriating recurring deposit instalments and Gramin Dak Jeevan Bima premiums collected from account holders during 2010–2011. Though he made entries in customers’ passbooks and affixed postal stamps, he failed to enter the amounts in the post office records and appropriated ₹5,266 for personal use. When discrepancies surfaced during inspection, he deposited the amount and admitted in his 28.04.2012 statement that he had used the money for household needs. A full-fledged inquiry under the 2011 Rules found both charges proved; defence assistance was provided, witnesses were cross-examined, and no procedural infirmity was shown. The Disciplinary Authority ordered removal; appeals before the Appellate Authority and CAT were dismissed. However, the High Court set aside the penalty, holding that the admission was coerced and that suspicion could not substitute proof. The Supreme Court rejected this approach, emphasising that (i) the admission was contemporaneous, (ii) the respondent never raised the “pressure” plea during inquiry, and (iii) documentary evidence established misappropriation, rendering the High Court’s interference impermissible.

Decision: The Supreme Court allowed the appeal, set aside the High Court’s judgment, and restored the punishment of removal from service, holding that the respondent’s misconduct was fully proved through a proper inquiry and that the High Court’s reappreciation of evidence and acceptance of belated explanations amounted to jurisdictional overreach. All pending applications were disposed of.