Supreme Court determined that the burden of proof in disciplinary proceedings varies with the specific charge against the respondent and their explanation. The court emphasized that the burden can shift depending on the respondent's response.

The court reaffirmed the limited scope of judicial review in departmental inquiries. Judicial review focuses on the decision-making process's legitimacy and evidence supporting findings, rather than re-evaluating merits.

The case concerned a Karnataka HC Division Bench affirming a single bench's decision to annul penalties in a disciplinary case. The respondent, a former Field Officer at the Mahadevapura Branch of State Bank of India, faced charges related to failing inspections and neglecting equitable mortgage stipulations.

The penalty was pay reduction and treating suspension as time served. The court noted the respondent didn't counter inspection charges after obtaining records, shifting the burden. Regarding equitable mortgage, evidence highlighted the Branch Manager and Field Officer's role.

The court found evidence supported the charges, justifying the imposed pay reduction under Rule 49(e) of State Bank of India (Supervising Staff) Service Rules. Even if some charges lacked proof, aligning penalty with proven charges, as per State of Orissa v. Bidyabhushan Mohapatra, was justifiable.

The penalty, being pay reduction, wasn't deemed excessive. The court concluded that the penalty's imposition was supported by evidence and didn't shock the conscience of the court.

Case Title: State Bank of India v. A.G.D. Reddy

Click here to read/download Judgment