J. D. JAIN versus THE MANAGEMENT OF STATE BANK OF INDIA & ANR.

J. D. JAIN versus THE MANAGEMENT OF STATE BANK OF INDIA & ANR.

The Tribunal's award was vitiated by a misconception of law, as it wrongly held that failure to examine Kansai rendered all evidence hearsay; confession and circumstantial evidence substantiated the misconduct. Strict rules of evidence are inapplicable in domestic enquiries, and proof of misconduct is sufficient without proof beyond reasonable doubt. High Court correctly quashed the Tribunal's order.

Parties
Appellant: J.D. Jain; Respondent No. 1: State Bank of India
Jurisdiction
India
Judgment Date
17 December 1981
Procedural Posture
Civil Appeal / Appeal by Special Leave From Delhi High Court Judgment Dated 18 October 1978 in Civil Writ Petition No. 1292 of 1975
Outcome
appeal dismissed
Legal Topics
Domestic Enquiry, Industrial Disputes, Jurisdiction of High Court, Evidence in Departmental Proceedings
Labour Law Constitutional Law Domestic Enquiry Industrial Disputes Jurisdiction of High Court Evidence in Departmental Proceedings

Case Brief

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Parties

J.D. Jain

Appellant

State Bank of India

Respondent No. 1

Procedural Posture

Civil Appeal / Appeal by Special Leave From Delhi High Court Judgment Dated 18 October 1978 in Civil Writ Petition No. 1292 of 1975

Legal Issues

  1. 1 Whether the High Court had jurisdiction to interfere with the award of the Industrial Tribunal under Article 226/227 of the Constitution
  2. 2 Whether the evidence relied upon in the domestic enquiry was hearsay and legally sufficient
  3. 3 Whether guilt must be proved beyond reasonable doubt in a departmental enquiry

Ratio Decidendi

The Tribunal's award was vitiated by a misconception of law, as it wrongly held that failure to examine Kansai rendered all evidence hearsay; confession and circumstantial evidence substantiated the misconduct. Strict rules of evidence are inapplicable in domestic enquiries, and proof of misconduct is sufficient without proof beyond reasonable doubt. High Court correctly quashed the Tribunal's order.

Court Disposition

appeal dismissed

Orders

  • High Court's order quashing the Tribunal's award affirmed
  • Appellant and respondent to bear their own costs