Summary and Analysis of State Bank of India & Others vs Ramadhar Sao

1. Heading of the Judgment

Case Name: State Bank of India & Others v. Ramadhar Sao
Citation: 2025 INSC 1010
Court: Supreme Court of India
Judges: Justice Rajesh Bindal and Justice Manmohan
Date of Judgment: August 20, 2025

2. Related Laws and Legal Principles

The judgment revolves around the following legal principles:

• Judicial Review in Disciplinary Matters: Courts cannot act as appellate authorities; they can only intervene if there is a violation of natural justice, procedural irregularity, or manifest injustice.

• Departmental Inquiry Standards: Findings of disciplinary authorities are based on preponderance of probabilities, not proof beyond reasonable doubt.

• Reasoning in Disciplinary Orders: If the disciplinary authority accepts the inquiry report, detailed reasons are not required.

• Punishment in Corruption Cases: Courts should be slow to interfere with penalties imposed in cases involving corruption, especially in public institutions like banks.

3. Basic Details of the Judgment

• Appellants: State Bank of India (SBI) and its officials

• Respondent: Ramadhar Sao (former employee of SBI)

• Background:
  Ramadhar Sao was a Class IV employee (Messenger) at SBI’s Agriculture Development Branch, Rammagar.
  In 2008, complaints were received that he was acting as a middleman for loan sanctions and taking bribes.
  A chargesheet was issued in 2010, and after a departmental inquiry, he was found guilty.
  The Disciplinary Authority dismissed him from service in 2011.
  The Appellate Authority reduced the punishment to "removal from service" with superannuation benefits in 2012.
  Sao challenged this before the Patna High Court, which set aside the punishment and ordered reinstatement with back wages.
  SBI appealed to the Supreme Court against the High Court’s order.

4. Explanation of the Judgment

a. Facts of the Case

Ramadhar Sao was accused of:

• Acting as a middleman for loan sanctions.

• Taking bribes from customers for facilitating loans.

• Unauthorized absence during an investigation.

Multiple customers (PW-1 to PW-5) testified during the inquiry that they paid bribes to Sao. The Field Officer (PW-6) confirmed procedural irregularities. Sao admitted his mistake and pleaded for mercy before the Disciplinary Authority, citing personal hardships.

b. Key Legal Issues

• Whether the High Court overstepped its jurisdiction in interfering with the disciplinary action.

• Whether the punishment was disproportionate to the misconduct.

• Whether the inquiry was conducted fairly and based on evidence.

c. Supreme Court’s Reasoning

• Scope of Judicial Review:
  The Supreme Court emphasized that judicial review is limited to checking procedural fairness, natural justice, and legality—not re-evaluating evidence.
  The High Court erred in acting as an appellate authority and substituting its own view for that of the disciplinary authority.

• Evidence and Admission:
  The inquiry was conducted fairly: Sao was given a chance to defend himself, cross-examine witnesses, and present his case.
  Multiple customers testified against him, and Sao himself indirectly admitted guilt by pleading for mercy.
  The Court held that disciplinary proceedings operate on preponderance of probabilities, not criminal standards of proof.

• Punishment:
  Corruption in public institutions like banks warrants strict action.
  The Appellate Authority had already shown leniency by reducing dismissal to removal with benefits.
  The High Court’s order to reinstate Sao with back wages was unjustified.

• Role of Class IV Employee:
  The High Court’s view that Sao, being a low-ranking employee, could not influence loan sanctions was misplaced.
  The proved misconduct was that he acted as a conduit for corruption, which is serious regardless of his rank.

d. Final Decision

• The Supreme Court allowed SBI’s appeal.

• The orders of the Single Bench and Division Bench of the High Court were set aside.

• The Appellate Authority’s order (removal from service with superannuation benefits) was restored.

• No costs were awarded.

5. Significance of the Judgment

• Reinforces Limited Judicial Review: Courts must not interfere with disciplinary actions unless there is a clear violation of natural justice or procedural law.

• Upholds Discipline in Public Institutions: Corruption, even by lower-level employees, must be dealt with strictly to maintain institutional integrity.

• Clarifies Standard of Proof: Departmental inquiries require only a preponderance of probability, not proof beyond reasonable doubt.

• Admission of Guilt: A plea for mercy can be construed as an indirect admission of misconduct.