The Karnataka High Court addressed a case concerning departmental disciplinary action following a criminal conviction for bribery, examining whether acquittal in the criminal proceedings should automatically lead to reinstatement of the employee. The dispute concerned a village accountant, formerly subject to compulsory retirement by the state government, whose dismissal followed a departmental enquiry that concluded he had accepted a bribe. The Karnataka State Administrative Tribunal (KSAT) had quashed the penalty, relying primarily on the employee’s acquittal in the criminal case. The state government challenged that decision before the High Court.
The factual background reveals that a complaint was filed alleging that the village accountant demanded a sum of ₹2,500 as gratification to mutate a name in revenue records. A trap was organized, the accused was caught in possession of cash amounting to ₹2,500, and a departmental enquiry was undertaken which, on October 24, 2019, found him guilty and recommended compulsory retirement. The imprisonment order was made effective on October 21, 2020. The employee approached KSAT, which set aside the retirement order, essentially on the ground that he had been acquitted in criminal proceedings.
On appeal, the High Court stressed that disciplinary proceedings and criminal trials operate under distinct standards of proof and cannot be conflated. The Court held that an acquittal in the criminal trial, especially on technical or procedural grounds, does not necessarily invalidate findings in a departmental enquiry where the standard is the preponderance of probabilities rather than proof beyond reasonable doubt. The High Court found that KSAT erred by reason of failing to appreciate this distinction, and by giving undue weight to the criminal acquittal.
The High Court examined the evidence, including oral testimony of key witnesses and the mahazar (official documents prepared during trap procedures), and concluded the departmental enquiry had led legally acceptable evidence establishing that the employee demanded and accepted illegal gratification, and that the trap was conducted in a lawful manner. The High Court held that KSAT’s interference with the tribunal’s decision was impermissible where it ignored the fundamental difference in standards of proof and the distinct nature of departmental proceedings vis-à-vis criminal trials.
The High Court reversed KSAT’s order, setting aside the reinstatement of the employee and restoring the penalty of compulsory retirement. The Court observed that interference was justified on grounds that the tribunal’s findings were perverse and inadequately reasoned in context of the evidence. While the High Court recognized that courts should not lightly interfere in disciplinary or misconduct proceedings, it reaffirmed the duty of courts to ensure accountability in the face of corruption allegations. The judgment underscores that acquittal in a criminal case does not automatically warrant quashing disciplinary penalties and that reinstatement must be governed by rigorous scrutiny of evidence and procedural propriety.
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