General Manager (P) Canara Bank v. Ganganarasimhaiah, 2025 INSC 1088 - Disciplinary Proceedings - Compulsory Retirement

Disciplinary Proceedings - When a Disciplinary Enquiry against a delinquent for alleged misconduct is initiated and in the said Disciplinary Enquiry, he/she is found guilty and subsequently punished, the court before which a challenge is made by the delinquent, is required to examine and determine the following aspects: - (i) Whether the enquiry was held by the competent authority? (ii) Rule of natural justice has been complied with or not; (iii) The conclusions arrived by the Disciplinary Authority are based on no evidence or the findings are perverse.- Strict rules of evidence are not applicable in the departmental proceedings and the charge against the delinquent can be proved on preponderance of probabilities.

Compulsory retirement - Compulsory retirement of an employee from the services does not mean that the employee is not entitled to retirement benefits, which can only be denied in a case of dismissal from service. (Para 40)

Case Info

Case Name and Neutral Citation

  • Case Name: The General Manager (P), Canara Bank v. Ganganarasimhaiah
  • Neutral Citation: 2025 INSC 1088

Coram

  • Coram: Hon’ble Mr. Justice J.K. Maheshwari and Hon’ble Mr. Justice Vijay Bishnoi

Judgment Date

  • Date of Judgment: 09th September, 2025

Caselaws and Citations Referred


The judgment refers to several Supreme Court decisions:

  1. B.C. Chaturvedi v. Union of India and OthersCitation: (1995) 6 SCC 749
  2. Deputy General Manager (Appellate Authority) and Others v. Ajai Kumar SrivastavaCitation: (2021) 2 SCC 612
  3. Standard Chartered Bank v. R.C. SrivastavaCitation: (2021) 19 SCC 281
  4. Indian Overseas Bank and Others v. Om Prakash Lal SrivastavaCitation: (2022) 3 SCC 803
  5. State of Rajasthan and Others v. Heem SinghCitation: (2021) 12 SCC 569
  6. State Bank of Bikaner and Jaipur v. Nemi Chand NalwayaCitation: (2011) 4 SCC 584

Other cases mentioned within the cited judgments:

  • Union of India v. H.C. Goel
  • Union of India v. S.L. Abbas
  • Administrator of Dadra & Nagar Haveli v. H.P. Vora
  • State Bank of India v. Samarendra Kishore Endow
  • Union of India v. G. Ganayutham
  • Bank of India v. Degala Suryanarayana
  • High Court of Judicature at Bombay v. Shashikant S. Patil

Statutes/Laws Referred

  • Industrial Disputes Act, 1947(Section 11A specifically discussed regarding the Tribunal’s jurisdiction)
  • Canara Bank Service Code(Chapter XI, Regulation 2(A), (i) and Regulation 4, Clause (b))
  • Constitution of India(Article 226, referenced in context of High Court’s jurisdiction)