Letters Patent Bench Cannot Reverse Writ Relief Merely on a Different View: Supreme Court Restores Order Against Removal of Periyar University Deputy Registrar Based on No Evidence
Case Name: R. Saravanan v. Periyar University represented by its Registrar & Others
Date of Judgment: 16 October 2026
Citation: 2026 INSC 1136
Bench: Justice Prashant Kumar Mishra and Justice Shree Chandrashekhar.
Held: The Supreme Court held that a Division Bench exercising jurisdiction under Clause 15 of the Letters Patent cannot interfere with a just and reasonable decision of the writ court merely because it takes a different view. Although a Letters Patent Appeal permits examination of questions of both fact and law, the appellate Bench must give due weight to the writ court’s discretion exercised on relevant considerations. Interference requires cogent grounds demonstrating a glaring error affecting the outcome, rather than a minor mistake or mere disagreement.
The Court further held that disciplinary findings unsupported by evidence are perverse and amenable to correction under Article 226 of the Constitution. Examining whether any evidence supports a finding is distinct from reappreciating the sufficiency of evidence. An inquiry officer must assess the material impartially and cannot act as a prosecutor or establish misconduct through conjectures, assumptions and legally impermissible inferences. The availability of a statutory appeal is a self-imposed restraint on writ jurisdiction, not an absolute bar to relief against an unlawful disciplinary punishment.
Summary: The Supreme Court allowed an appeal by R. Saravanan, a Deputy Registrar of Periyar University, against a Madras High Court Division Bench judgment restoring his removal from service. The Single Judge had interfered with the punishment after finding that the disciplinary conclusions rested on no evidence. The Division Bench reversed that relief upon taking a different view of the inquiry material.
Saravanan was appointed as Assistant Registrar on 2 May 2000 and subsequently served as Deputy Registrar. Following allegations concerning assets disproportionate to his known sources of income, the University constituted an inquiry committee and later appointed a one-man commission headed by a retired judicial officer. The University ultimately based his removal, effective from 27 July 2013, on three charges: influencing affiliation for a college in which his wife was a managing trustee, acquiring a house allegedly in his mother’s name without permission, and purchasing a Santro car allegedly beyond his regular sources of income.
The Supreme Court rejected Saravanan’s objections to the constitution and procedural validity of the one-man commission. It found that the competent authority had appointed the commission under the applicable service rules, that Saravanan understood the disciplinary nature of the proceedings, and that he had received sufficient opportunity to defend himself. Nevertheless, procedural validity did not cure the absence of evidence supporting the findings on which the punishment rested.
On the affiliation charge, the commission had treated the possibility that Saravanan’s position “could have” influenced the decision as sufficient to establish misconduct, without identifying incriminating material. On the house-property charge, it inferred ownership from his repayment of a housing loan as a co-borrower and his failure to produce documents establishing his mother’s ownership. On the vehicle charge, it treated failure to produce permission for the purchase and loan as establishing the allegation concerning acquisition beyond his means. The Court found that the disciplinary conclusions rested on conjectures and impermissible inferences rather than essential evidence proving the alleged misconduct.
The Court also criticised the disciplinary authority for accepting the commission’s report without recording reasons addressing these deficiencies. It affirmed that the Single Judge had acted within the permissible scope of judicial review by identifying a case of no evidence, rather than substituting an assessment of the weight of evidence.
Addressing the scope of intra-court appeals, the Supreme Court clarified that a Letters Patent Appeal does not carry the restrictions applicable to a second appeal under Section 100 of the Code of Civil Procedure. Its wider scope, however, does not justify routine interference with the writ court’s reasoned exercise of discretion. In this case, the Division Bench had displaced a well-reasoned decision without cogent or justifiable grounds.
Decision: The appeal was allowed. The Supreme Court set aside the Madras High Court Division Bench judgment and restored the Single Judge’s decision of 2013 interfering with Saravanan’s removal from service.