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:
- B.C. Chaturvedi v. Union of India and OthersCitation: (1995) 6 SCC 749
- Deputy General Manager (Appellate Authority) and Others v. Ajai Kumar SrivastavaCitation: (2021) 2 SCC 612
- Standard Chartered Bank v. R.C. SrivastavaCitation: (2021) 19 SCC 281
- Indian Overseas Bank and Others v. Om Prakash Lal SrivastavaCitation: (2022) 3 SCC 803
- State of Rajasthan and Others v. Heem SinghCitation: (2021) 12 SCC 569
- 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)
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What all aspects should be considered while considering a challenge against Disciplinary Enquiry? #SupremeCourt explains: https://t.co/nMOSVHrIj0 pic.twitter.com/G5xFJzpP6k
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Compulsory retirement of an employee from the services does not mean that the employee is not entitled to retirement benefits.#SupremeCourt https://t.co/nMOSVHrIj0 pic.twitter.com/kJwHr1boK9
— CiteCase 🇮🇳 (@CiteCase) September 10, 2025