Supreme Court Restores Dismissal of Bank Manager; Holds No Parity in Punishment with Lower-Rank Co-Delinquents

Case Name: Punjab & Sind Bank v. Raj Kumar
Citation: 2026 INSC 313
Date of Judgment/Order: 02 April 2026
Bench: Hon’ble Mr. Justice Dipankar Datta; Hon’ble Mr. Justice Satish Chandra Sharma

Held: The Supreme Court held that parity in punishment cannot be claimed merely because co-delinquents received lesser penalties, especially where the delinquent holds a higher position involving greater responsibility, and that courts should not interfere with disciplinary punishment unless it is shockingly disproportionate or perverse.

Summary: The case arose from disciplinary proceedings against a Senior Manager of Punjab & Sind Bank, who was dismissed from service for misappropriation of customer funds in connivance with other employees. While the co-delinquents, a gunman and another officer, were awarded lesser punishments, the respondent was dismissed. The High Court interfered with the punishment on the ground of discrimination under Article 14 and modified it to compulsory retirement. Before the Supreme Court, the issue was limited to whether such interference was justified. The Court examined settled principles governing judicial review of disciplinary action and reiterated that courts must exercise restraint and interfere only where punishment is shockingly disproportionate. It held that the respondent, being a Senior Manager, held a position of higher trust and accountability, and therefore could not be equated with lower-ranking co-delinquents. The differentiation in punishment was justified by the nature of duties, level of responsibility, and gravity of misconduct attributable to the respondent. The Court found that the High Court erred in applying the principle of parity without considering these distinguishing factors, and that the punishment imposed did not shock the conscience of the Court.

Decision: The Supreme Court allowed the appeal, set aside the judgments of the Single Judge and Division Bench of the Delhi High Court, and restored the order of dismissal from service imposed by the disciplinary authority, with parties directed to bear their own costs.