Judgment reinforces limited judicial review scope in departmental inquiries, focusing on procedural adherence and natural justice principles
In a decisive ruling, the Allahabad High Court has upheld the Uttar Pradesh State Road Transport Corporation's (UPSRTC) decision to remove conductor Mohd. Arif from service following allegations of carrying ticket-less passengers. The judgment, delivered by Justice Amitabh Kumar Rai on December 19, 2025, dismissed the writ petition filed by Arif challenging both the removal order dated May 31, 2002, and the subsequent appellate rejection dated September 10, 2002.
The case stems from an incident on March 9, 1990, when an inspection team found 30 passengers travelling without tickets on a bus operated by Arif, despite having paid the fare. The inspection, led by Heera Lal Upadhyay, Senior Centre In-charge, resulted in charges of misconduct, attempted embezzlement, corruption, and violation of duty against Arif.
Despite Arif's defense highlighting procedural lapses and alleged bias in the inquiry process, the court emphasized the limited scope of judicial review in departmental inquiries. Justice Rai stated that the court's role is confined to ensuring that inquiries adhere to prescribed procedures and natural justice principles, rather than reassessing evidence or punishment severity.
The judgment referenced several Supreme Court rulings underscoring the principle that strict evidence rules do not apply in departmental inquiries and that reliance on independent witnesses is not mandatory. The court found that Arif had been given ample opportunity to present his defense and witnesses during the inquiry process.
Furthermore, the court dismissed claims that the Regional Manager lacked the authority to issue the removal order, affirming that higher authorities within the UPSRTC can exercise such powers under service regulations.
This ruling reinforces the judiciary's stance on maintaining procedural integrity and fairness in departmental inquiries, while limiting intervention to instances of significant procedural violations.
Bottom Line:
Disciplinary proceedings - Allegations of bias and non-compliance with procedural norms - Scope of judicial review in departmental inquiries is limited to ensuring adherence to the prescribed procedure and principles of natural justice, and not to re-evaluate evidence or assess the adequacy of punishment.
Statutory provision(s):- Uttar Pradesh State Road Transport Corporation Employees (Other Than Officers) Service Regulations, 1981
Mohd.Arif v. U.P.State Road Transport Corp., (Allahabad)(Lucknow) : Law Finder Doc Id # 2824803
