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As per case facts, disciplinary proceedings were initiated by the United Commercial Bank against P.C. Kakkar for misconduct as Assistant Manager. He was dismissed after charges were established, and his
...appeals were rejected. The High Court, however, quashed the dismissal and ordered reinstatement with lesser punishment (75 percent salary deprivation, severe warning, full seniority), citing discrimination compared to another officer, M.L. Keshwani, who received a lighter penalty for what the High Court deemed more serious allegations. The question arose regarding the scope of judicial interference in the quantum of punishment, especially when the findings of guilt were not challenged. Finally, the Supreme Court ruled that judicial review in disciplinary cases, when challenging punishment as "arbitrary" under Article 14, is limited to Wednesbury principles (secondary review). Courts should not substitute their own judgment unless the punishment "shocks the conscience" due to being illogical, procedurally improper, or in outrageous defiance of logic or moral standards. The Court stressed the need for specific recorded reasons for finding a punishment disproportionate, which the High Court failed to provide. It also clarified that a co-delinquent's lighter punishment for contextually different allegations is not a valid ground for interference. Emphasizing the higher standards of honesty and integrity required from bank officers and the serious nature of Kakkar's misconduct, the Supreme Court remitted the case back to the High Court for fresh consideration of only the punishment aspect, deeming all other findings as final.
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